PUTTRU ONLINE PRIVACY POLICY

PUTTRU ONLINE PRIVACY POLICY

 

INTRODUCTION

 

Welcome to the Puttru (or PUTTRU TECHNOLOGIES LIMITED)'s Privacy Policy.


Puttru respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

1. IMPORTANT INFORMATION AND WHO WE ARE

 

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Puttru collects and processes your personal data through your use of this website, including any data you may provide through this website.

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

CONTROLLER

Puttru (collectively referred to as "we", "us" or "our" in this privacy policy) is the controller and is responsible for your personal data and for this website.

 

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our Data Security Officer in the following ways:

Full name of legal entity: PUTTRU TECHNOLOGIES LIMITED

Email address: privacy@Puttru.com 

Postal address: at 29 Mambilla St, Three Arms Zone, Abuja, Nigeria

Telephone number: +234 8144572981

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 19 Feb. 20.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2. THE DATA WE COLLECT ABOUT YOU

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Data includes first name and last name.
  • Contact Data includes email address.
  • Technical Data includes internet protocol (IP) address, data related to your device/browser and first party cookies.
  • Profile Data includes who you represent and your interests.
  • Usage Data includes information about how you use our website, products and services, which we collect through Google Analytics and HotJar.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

 

We will collect information about you through the following means:

  • When you sign up to our team by filling in our ‘’Sign Up to Puttru’’ form or any other Puttru forms.
  • If you contact us via our online form, email, telephone or social media.
  • When you post on our social media sites (Twitter and LinkedIn).
  • From volunteering with Puttru.
  • By taking part in one of our events.
  • When you participate in market research.
  • We may also collect personal information about you available from the public domain such as company websites, news archives or social networks.
  • When you navigate through our website, certain technical information is gathered using Google Analytics. This information includes internet protocol addresses, internet tags, navigational data, the internet platform you are using and device identifiers.  

 

4. HOW WE USE 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 contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party).
  • Where we need to comply with a legal obligation.

 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at privacy@Puttru.com.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Profile

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics  to operate our electronic marketplace as well as to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(c) Profile

(d) Marketing and Communications

  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

To produce Market Intelligence reports for public consumptions

(a) Technical

(b) Usage

(c) Marketing and Communications

Necessary for our legitimate interests (developing our business and supporting an enabling ecosystem, additional revenue source)

 

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

 

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

 

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time at privacy@Puttru.com.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service experience or other transactions.

 

COOKIES

We use cookies in order to help us improve your user experience and work out which types of content are more popular than others. A cookie is a file which is stored on your computer or mobile device, via your web browser. Cookies enable this website to recognise when somebody revisits it. By using this site you are allowing us to set these cookies.

 

If you do not wish to receive cookies you can easily modify your web browser to refuse cookies, or to notify you when you receive a new cookie. For more information about cookies and for instructions on how to stop cookies being installed on your computer, please see www.allaboutcookies.org and www.allaboutcookies.org/manage-cookies    

Cookies in use by this website:


We use session cookies to recognise movements around our website. This helps us remember your selections and preferences and makes your overall experience faster and more user friendly.

 


Other Third Party Cookies set by Puttru:

 

  • Google Analytics/HotJar: We use Google Analytics to see which areas of our website and Platform are the most popular. This data does not tell us anything specific about you such as your name or address, but it does allow us to make observations such as the number of people from a particular country visiting our website and which particular pages.
  • LinkedIn/Twitter: We use LinkedIn/Twitter cookies in order to enable you to easily share articles with your professional network.

 

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

  • External Third Parties, which may sometimes be based outside of Europe including external consultants, investors or energy companies.
  • Certain partners based on a collaboration agreement. This may include both regional and national government organisations and will occur mainly for the purpose of data analytics.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

6. INTERNATIONAL TRANSFERS

If you are in the European Economic Area, the Standard Contractual Clauses (processors) approved by the European Commission Decision C(2010)593 set out in Schedule 3 to the Agreement or any subsequent version thereof released by the European Commission (which will apply automatically), and which includes Annex A (Details of the Transfer) and Annex B (Technical and Organisational Measures) to Schedule 3 (the "International Transfer Clauses") shall apply to the transfer of Client Personal Data to Puttru. If there is any inconsistency between any of the provisions of the International Transfer Clauses and the provisions of the rest of the Agreement, the provisions of the International Transfer Clauses shall prevail

 

7. DATA SECURITY

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Puttru shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including the measures set out in Schedule 2 and (as appropriate) any other measures listed in Article 32(1) of the GDPR.

 

 

8. DATA RETENTION

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


As a general rule, we will retain the personal data of users for as long as they remain customers of Puttru. Following this, personal data will be kept for no more than 5 years. We will inform users prior to deleting their data and provide them with the option to continue to remain on our database.

 

9. THIRD PARTIES

Puttru may make use of the following external third parties:

  • Service providers providing IT and system administration services.
  • Professional advisers including external consultants engaged as investment experts and helping companies to put together investment packages.
  • HM Revenue & Customs, regulators and other authorities who may require reporting of processing activities in certain circumstances.
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