PRIVACY POLICY
The Guardian acknowledges that the right to privacy is a fundamental right guaranteed by Section 37 of the 1999 Constitution of the Federal Republic of Nigeria, and hence takes your privacy of information very seriously.
Please read this Privacy Policy carefully as it describes how The Guardian (“we”, “us” or “our”) collects, uses, shares, and transfers information when you use any of The Guardian’s platforms. The Guardian’s platforms in this context refers to all our websites, mobile sites, mobile apps on iOS, emails or any other technology or services you may use to interact with us.
INFORMATION WE COLLECT
We collect and use your personal information strictly in line with the Nigeria Data Protection Act, 2023 (NDPR), and other applicable local laws, rules and regulations on the processing of personal data.
We may collect the following types of information:
- Information You Provide Voluntarily
- Account Information: When you create an account or subscribe, you provide your name, email address, and password.
- Payment Information: If you subscribe to our service, payment processing is handled by third-party payment processor. We do not store your full payment card details, but we may receive transaction details such as the date and time a payment was made.
- Correspondence: Information you provide when you contact us for customer support, feedback, or inquiries.
- Information Collected Automatically
- Device and Usage Data: Information about how you access and use our platforms, including your browser type, browser language, device model, operating system version, IP address, unique device identifiers (like the IDFA), mobile network information, app activity (pages viewed, time spent in app, articles read), and crash reports.
- Location Information: We may derive your general location (e.g. city, state, country and Zip code) associated with IP address, information derived through WiFi triangulation, and precise location information from GPS-based functionality on your mobile devices or from your use of our Mobile Apps, and with your consent, your precise GPS information. When using our mobile apps, we may also, with your explicit permission via the iOS prompt, collect precise geolocation data to offer localized news or weather, which you can revoke at any time in your device settings.
- Usage Information: including files you download, domain names, landing pages, your browsing activity, what you click, scrolling and keystroke activity, pages viewed, advertising viewed or visited, forms or fields you complete or partially complete, search
terms, whether you open an email and your interaction with the content, access times, and error logs, and other similar information.
- Viewing Behaviour: including the content you view, how long you watch each video, the quality of the service you receive (e.g. buffering, load times) as well as advertisements you have been shown or interacted with.
- Offline Information: Certain information may also be stored while you are offline and transmitted to us when you next connect to the Internet, regardless of where you connect from or the device you use to connect.
- Social Media Information: If you visit any of our platforms on a device on which you also use for social networks or if you interact with us through a social media service or other platform, we may have access to some information you provide to that social network or platform such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, and the people/sites you follow, the posts or the ‘likes’ you make.
- Analytics Data: We use third-party analytics tools (e.g. Google Analytics for Firebase, Mixpanel) to understand user engagement and improve our platforms.
The Guardian’s intention is not to seek or collect “Sensitive Personal Data” through our platforms. “Sensitive Personal Data” means personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or concerning physical or mental health, sexual orientation, criminal record, any other sensitive personal information. We shall not seek or process your sensitive personal data unless: (a) you give and not withdraw consent to the processing for the specific purpose or purposes for which it will be processed; (b) processing is necessary for the purposes of performing our obligations as data collectors or is permitted by the law.
HOW WE USE INFORMATION COLLECTED
We use the information we collect for the following purposes:
- Provide and Maintain our platforms: To deliver news content and services you request.
- Manage Your Account: To administer your subscription and provide customer support.
- Personalization: To customize your experience and deliver relevant news and advertisements based on your interests and reading history.
- Improve Our Services: To analyze usage trends, troubleshoot technical issues, and improve the functionality and performance of the App.
- Communication: To send you newsletters, updates, and marketing communications, subject to your preferences.
- Security and Legal Compliance: To protect the security of our services, detect and prevent fraud, and comply with legal obligations.
PROTECTING YOUR INFORMATION
We are committed to ensuring that your information is secure. To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place
appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect electronically. However, no internet or mobile transmission is completely secure, and we cannot guarantee absolute security. The Guardian cannot be responsible for the security of electronic transmissions of your personal data.
HOW WE SHARE YOUR INFORMATION
The Guardian may disclose your personal data to a third party in order to: (i) enforce our platforms Terms of Use; (ii) in urgent circumstances to protect personal safety, the public or our platforms; (iii) for regulatory compliance purposes; or (iv) as otherwise set out in this Privacy Policy.
Be assured that we will not share or sell your personal information for monetary value. However, we may share your information with the following categories of third parties:
- Members of The Guardian Group: This includes sister-organisations, subsidiaries, and affiliates.
- Service Providers: Third-party vendors who perform services on our behalf, such as analytics providers (e.g. Google Analytics for Firebase), hosting services, and customer support platforms.
- Advertising Partners: We may share device identifiers and usage data with advertising partners to facilitate interest-based advertising.
- Legal Requirements: We may disclose information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
- Business Transfers: Information may be transferred to a successor entity in the event of a merger, acquisition, or asset sale.
It is also possible that we may be required by law to disclose your personal data pursuant to applicable law, statute, rule, regulation or professional standard, or through judicial or other government subpoenas, warrants, or orders, potentially, in any country where we do business.
HOW TO CONTROL YOUR DATA
- iOS Privacy Control
You have control over certain data collection on our mobile apps through your iOS device settings:
- Location Data: You can turn off precise location sharing in your iPhone’s Settings > Privacy & Security > Location Services.
- Tracking Transparency: We adhere to Apple’s App Tracking Transparency (ATT) framework. We will ask for your consent before tracking your activity across other companies’ apps and websites for advertising purposes. You can manage this in Settings > Privacy & Security > Tracking.
- Communication Preferences
You may opt out of receiving marketing emails from us by following the unsubscribe instructions provided in those emails.
HOW WE USE COOKIES
Cookies are small pieces of data that a website sends to your computer’s web browser while you are navigating through it. Once you agree to a cookie, the data is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our platforms in order to tailor it to client/subscribers’ needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better platform, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any personally identifiable information about you, other than the data you choose to share with us.
If you are concerned about cookies, most web browsers allow individuals to decline cookies. In most cases, you may refuse or delete one or more cookies and still have access to our platform, but our platform functionality may be impaired. After you finish browsing our platform, you may delete its cookies from your system if you prefer.
THIRD-PARTY LINKS
Our websites may link to other websites which do not operate under our privacy practices. When you link to other websites, The Guardian’s privacy practices no longer apply. We encourage members to review each site’s privacy policy before disclosing any personally identifiable information.
DATA RETENTION
We will only retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
YOUR RIGHTS
The Guardian is based in, and operates from, Nigeria. Accordingly, this Privacy Policy is governed by the relevant laws of Nigeria. Where granted by the law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you. In certain circumstances, you may also request that we cease processing your personal data.
If you would like to make a request to access, review or correct the personal data we have collected about you, please contact us at: [email protected]. We are committed to providing reasonable and practical access to subscribers to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, we will delete identifying information from current operational systems. The Guardian does not assume responsibility for verifying the ongoing accuracy of the content of personal information.
INTERNATIONAL USERS
Our platforms are uniquely designed for global use and accessibility. Regardless of where you use or access our platforms, applications, products, or services, your information may be transferred to and maintained on our servers in Nigeria.
We understand that European Economic Area and the UK laws grant residents the rights to access, correct, delete, or restrict the processing of your data. Such subscribers also have the right to data portability and to object to processing.
Similarly, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) grants California residents the right to know what information is collected, the right to request deletion of personal information, the right to opt-out of the “sale” or “sharing” of personal information (as defined under CCPA), and the right to non-discrimination for exercising your privacy rights.
While we are committed to respecting the rights of international users (where they do not conflict with Nigerian laws), please note that any information we obtain about you will be stored in accordance with Nigerian privacy laws, regulations and standards, which may not be equivalent to the laws in your country of residence. By using our services, you consent to the collection, transfer, storage and processing of information to and in Nigeria.
CHILDREN
The Guardian knows the importance of protecting children’s privacy, especially in an online/digital environment. Therefore, our platforms are not designed for, or directed at, individuals under the age of 13. We do not intentionally collect or maintain personally identifiable information from children under 13. If you are a parent or guardian and you learn that your child(ren) or ward(s) under the age of 13 has provided us with personal information, please contact us at: [email protected]. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we will remove that information from our servers.
CONSENT: CHANGES TO PRIVACY POLICY
By using any of our platforms, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about
the changes on our platforms. The date at the top of the Privacy Policy tells you when it was last updated. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted. If you use this online service after the changes are posted, you have agreed to the changes.
HOW TO CONTACT US
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: [email protected].