INVITA Privacy Policy

This Privacy Policy applies to all of the products and services offered by INVITA collectively referred to as INVITA’S “services”. In addition, where more detailed information is needed to explain our privacy practices, we shall post supplementary privacy notices to describe how particular services process personal information.

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the “Last Updated” date above to indicate when those changes will become effective.

Collection and Use of Information

We explain our “processing” of PII (defined below) through using words throughout such as “collect,” “record,” “extract,” and “use”. In addition to their plain meaning, these words mean any operation which is performed upon such personal information, whether or not by automatic means, including organizing, structuring, storing, altering, retrieving, consulting, disclosure by transmission, dissemination, restricting, erasing, and destroying, as applicable to the particular situation. All individuals whose responsibilities include the processing of Personal Information on behalf of INVITA are expected to protect that PII by adherence to this Privacy Policy.

Information Collected or Received from You

We collect information you provide directly to us. For example, we collect information when you participate in any interactive features of our Services (including public features such as blogs, messaging and community forums), fill out a form, request customer support, provide any contact or identifying information, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, credit card information and other contact or identifying information you choose to provide.

Registered User Information

If you create an Account, we’ll extract from your Third Party Account (as applicable) certain personal information that can be used to identify you, such as your name and email address (“Personally Identifiable Information” or “PII”) that the privacy settings that you have established on your Third Party Account permit us to access. In addition, if after you create an Account, you connect it with one of your Third Party Accounts, we’ll be able to access and collect certain information, including your PII, that your privacy settings on such Third Party Account permit us to access. We will also use End User Data from the Third Party Accounts to which you provide us access and that you submit to us and we will use such End User Data in connection with provision of the Services to you. We may also collect your gender, zip code and other information that is not considered PII because it cannot be used by itself to identify you.

Financial Information

When you enter into a Transaction, we may collect your Payment Information.

Information We Collect Automatically When You Use the Services

Like many website owners and operators, we use automated data collection tools such as Cookies, Web Beacons, and Social Media Widgets to collect certain information.

"Cookies"are small text files that are placed on your hard drive by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. We may also use third party cookies from Google, Facebook, and Twitter to measure the amount of End User conversions (how many ads result in sales) for our own advertising purposes and for Ad Campaigns on behalf of Registered Users. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some other third-party services providers that we engage may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.

"Web Beacons" (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services and to monitor how many visitors view our Services. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages.

"Social Media Widgets" “Social Media Widgets” are social media features such as Facebook Share, Twitter Follow, YouTube Subscribe, Facebook Messenger Subscribe, and Pinterest Pin. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

Automated Data Collection

Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both Registered Users and non-Registered Users (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, other device identifiers, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on, and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. Such third parties include analytics service providers such as Google and Intercom.

Location Information

When you create your Account using a Third Party Account (as applicable) and when you connect your Account with your other Third Party Accounts, we may collect and store information about your location if your privacy settings on such Third Party Account permits us to access such information. We may use location information to improve and personalize our Services for you. By accessing and using our Services, you consent to the processing and transfer of your information in and to the Nigeria and other countries.

USE OF PERSONAL DATA

In addition to some of the specific uses of personal data we describe in this Policy, we may use information that we receive to:
  1. Process payments for use of the Services;
  2. Help you efficiently access your information and features of the Services;
  3. Remember information so you will not have to re-enter it during your visit or the next time you visit the Services;
  4. Provide personalized content and information to you and others, which could include online ads or other forms of marketing;
  5. Provide, improve, test, and monitor the effectiveness of our Services;
  6. Calculate settlements for content owners;
  7. Develop and test new products and features;
  8. Monitor metrics such as total number of visitors, traffic, and demographic patterns;
  9. Diagnose or fix technology problems; or
  10. Detect, investigate and take all steps necessary to address misuse of the Services.

SHARING INFORMATION WITH THIRD PARTIES

We may share your personal data with our affiliates on whom we rely to provide the Services and for the purposes outlined in this Privacy Policy. We may also share information and personal data with third parties other than our affiliates in the following situations: a) Parties with whom we may share your personal data. • Rights Holders - INVITA allows you to listen to and view content from third party rights holders. INVITA shares information with the rights holders that license this content to INVITA. The data that INVITA shares with the rights holders is in a de-identified format that does not identify you directly, unless you opt into the sharing of your personal data. • Service Providers - We may share User Content and your information (including but not limited to, information from cookies, log files, metadata and usage data) with third party organizations that help us provide the Services to you, including telecommunications companies with whom you have a contractual relationship and through which you may receive access to the Services (for example through a bundled package), and payment processors (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services under reasonable confidentiality terms. • Your Financial Institution. In the event you contest or dispute Subscription charges, we may share information collected in accordance with this policy, as reasonable, to assist your credit card company or financial institution to investigate and resolve your claim. • Acquisition - If we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If INVITA or substantially all its assets are acquired by or sold to a third party, your personal data may be among the transferred assets. The buyer or transferee will have to honor the commitments we have made in this Policy. b) Parties with whom you may choose to share your User Content. Any information (e.g., name) or User Content (e.g., picture) that you voluntarily share or disclose for posting to the Services may become available to the public. This can also include parties to whom you have given us consent to share such personal data, as further described above. c) Responding to legal requests and preventing harm. We may access, preserve and share your personal data in response to a legal request (such as a search warrant, court order or subpoena) if we have a good belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of Nigeria where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect INVITA, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. By allowing for sharing and use of personal data for these purposes, INVITA is not assuming any affirmative duty to undertake such actions.

Opt-Out

a. Email Communications. We may periodically send you free e-mails that directly promote our Services. When you receive such promotional communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive. We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service or this Privacy Policy, or information about billing. b. PII Collection. Where you have consented to the collection of PII, you may rescind such consent by following one of the following two links: • Global Opt-out and deletion of all of your PII: Opt Out • Marketing communication only: Opt Out Even if you opt out, we may still collect and use information about you that is not PII regarding your activities on our Services and/or information from the advertisements on third party websites for non-interest based advertising purposes, such as to determine the effectiveness of advertisements. Modifying Your Information You may inquire as to how we use your PII, request access to PII, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to ***INVITA.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of PII held about you by us. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. Although we make good faith efforts to provide a User access to their PII, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your PII. The Security of Your Information We take reasonable administrative and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. Links To Other Sites Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-Party Service”). Any information that you provide on or to a Third-Party Service or that is collected by a Third-Party Service is provided directly to the owner or operator of the Third-Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-Party Services that you access. Data Retention a) By registering for, accessing, visiting or otherwise using the Services, you consent to the transfer of your personal data to anywhere where INVITA or its Service Providers maintain facilities, including facilities in another country. b) We use commercially reasonable safeguards to help keep your personal data secure and to protect against accidental loss, destruction or damage. Only a limited number of personnel with a legitimate business or legal need are given access to users’ personal data. However, we cannot ensure the security of any information you transmit to INVITA or guarantee that information on the Services may not be accessed, used, disclosed, altered, or destroyed. c) You are responsible for maintaining the secrecy of any non-public information that you provide INVITA, accessing the Services and making payments from a secure computer or device, and for controlling access to emails between you and INVITA, at all times. Any social media services that you use to connect to the Services (e.g., Facebook, Twitter) may also affect your information; we are not responsible for the functionality, privacy, or security measures of any other organization. d) User Content that you provide to the Services may be retained and made publicly available on the Services indefinitely, consistent with the Terms and Conditions of Use. e) Information we collect or receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

International Transfer

Your PII may be transferred to, and maintained on computers located outside of your state, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside Nigeria and choose to provide your PII to us, we may transfer your PII to Nigeria and process it there.

Our Policy Toward Children

The Services and their content are not directed at children under the age of 18. INVITA does not knowingly collect or solicit any personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services. In the event that we learn that we have collected personal data from a child under age 18 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any personal data from or about a child under 18, please notify us immediately by sending an email to ******@INVITA.com.

CONDITIONS OF USE AND REVISIONS TO THIS POLICY

If you choose to visit, access, or use the Services, your visit, access and/or use and any dispute over privacy is subject to this Policy and INVITA’s Terms and Conditions of Use, including limitations on damages, resolution of disputes — including an agreement to arbitrate, to not proceed in court or on a class or collective basis, and to not have the right to resolve disputes by a trial in court before a judge — and application of applicable Federal Law and the Laws of Lagos State, Nigeria. If we suspect misuse of the Services, we may combine the personal data we have collected in accordance with this Privacy Policy with other information in order to investigate the extent of the misuse and who is responsible. The Services are subject to constant improvement and future changes may influence how we collect, use, share, and store your personal data. This Policy will be updated to reflect such changes, changes in legal framework or improvements in how we handle personal data. Unless stated otherwise, INVITA’s most recent Privacy Policy applies to all information that we have about you. We may e-mail periodic reminders of the Privacy Policy and Terms and Conditions of Use, but you should check the INVITA website to see recent changes. Your continued visitation, access and/or use of the Services after any revisions or modification to this Policy will constitute acceptance of such changes.

Questions

Please contact us at invitaapp@mobilexcetera.com if you have any questions about our Privacy Policy.

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