Prowox Int'l Co. Ltd and its affiliates (collectively, "Prowox") respects your individual privacy and value the confidence of its associates, customers, vendors and others with whom we do business. Snapnet strives to collect, use and disclose your Personal Information in a manner consistent with the laws of the countries in which it does business, and prides itself on upholding the highest ethical standards in its business practices.

This global Privacy Policy sets forth the general privacy principles that Snapnet follows with respect to your Personal Information that it gathers, processes, stores and discloses in its business operations.

Scope

This Privacy Policy applies to all Personal Information, in any format or medium, relating to our, customers, vendors and others who do business with Snapnet.

Definition

For purposes of this Privacy Policy, the term "Personal Information" means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Privacy Principles

Prowox when gathering, processing, storing, using or disclosing your Personal Information, shall follow these principles:

Legal Basis for Processing. Snapnet collects, processes, uses, shares, and retains your Personal Information in accordance with all applicable data privacy and information security laws, regulations, and directives. Snapnet collects and uses Personal Information when the Data Subject provides consent to specific processing (as described below), or to enable Snapnet to comply with a contractual obligation, to undertake a legitimate interest, and/or to comply with legal and regulatory requirements.

Notice and Consent. This Privacy Policy sets forth when we collect Personal Information about you, the purposes for which we collect and use the Personal Information, the types of third parties to which Snapnet discloses or may disclose that information, and the choices and means we offer you for limiting the use and disclosure of your Personal Information. When you provide information to Snapnet you consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and other applicable Snapnet privacy policies. You may, as provided by applicable law, be free to refuse or withdraw your consent upon reasonable notice. Snapnet will endeavor to advise you of the consequences of withdrawing your consent.

Privacy and Security. Snapnet's products and services, including this Site, are developed and designed to protect the privacy and security of your Personal Information.

Information We Collect

We may obtain Personal Information about you from various sources, including this and other Snapnet websites, mobile applications, courses offered (whether online or in person), when you call or email us or communicate with us through social media, or when you participate in surveys, events or other promotions. We also may obtain information about you from our parent, affiliate or subsidiary companies, business partners and other third parties.

The types of personal information we may obtain include:

• Your contact information (such as name, Twitter handle, postal and email address, or phone number).
• Contact information of friends or other people you would like us to contact.
• Username and password for the account you may establish on our sites.
• Payment details (including payment card number, security code, expiration date, cardholder name and billing address).
• Shipping information (including the shipping address and phone number).
• Course preferences.
• Course locations.
• Demographic information (such as gender).
• Information you provide by interacting with us through social media, including photographs.
• Shopping behavior and preferences, and a record of the purchases you make on our websites.
• Other details that you may submit to us or that may be included in the information provided to us by third parties.

In addition, when you visit our websites or use our mobile applications, we may collect certain information by automated means, such as cookies, web beacons and other technologies. A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We also may use third-party website analytics tools (such as Google), that collect information about visitor traffic on our sites and mobile applications. The information we may collect by automated means includes:

• Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser and operating system type).
• URLs that refer visitors to our sites.
• Dates and times of visits to our sites.
• Information on actions taken on our sites (such as page views and site navigation patterns).
• A general geographic location (such as country and city) from which a visitor accesses our websites.
• Search terms that visitors use to reach our sites.



How We Use The Information We Collect

We may use the information we obtain about you to:

• Manage and maintain your account on the sites.
• Identify and authenticate site visitors.
• Provide products, courses or other services you request.
• Process, validate, confirm, verify, deliver and track your purchases (including by processing payment card transactions, arranging shipping and handling returns and refunds, and contacting you about your orders, including by telephone).
• Maintain a record of the purchases you make on our sites and identify and retrieve electronic shopping baskets that you may have created.
• Maintain a record of the courses you have taken.
• Respond to your questions and comments and provide customer support.
• Communicate with you about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you.
• Enable you to communicate with us through our blogs, social networks and other interactive media.
• Publish your testimonials about Snapnet, including on our websites and blogs, and on social networks (if we choose to publish your testimonial, we will include only your first name, last initial, city and state).
• Manage your participation in our events, sweepstakes and other promotions.
• Tailor our products and services to suit your personal interests and the manner in which visitors use our sites, applications and social media assets.
• Operate, evaluate and improve our business and the products and services we offer.
• Analyze and enhance our marketing communications and strategies (including by identifying when emails sent to you have been received and read).
• Analyze trends and statistics regarding visitors’ use of our sites, mobile applications and social media assets, and the purchases visitors make on our sites.
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users.
• Comply with applicable legal requirements and industry standards and our policies.
• Other routine and common business functions.



We may combine the information we collect with publicly available information and information we receive from our parent, affiliate or subsidiary companies, business partners and other third parties. We may use that combined information to enhance and personalize your shopping experience with us, to communicate with you about products, services and events that may be of interest to you, for other promotional purposes, and for other purposes described in this section.


We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.




Online Advertising And Tracking

When you browse a Snapnet web site, you do so anonymously, and except as set forth herein Personal information is not collected. Some areas of our web sites, however, may request that you voluntarily supply us with Personal Information, including your name, email address or the like for purposes such as correspondence, site registration, making a purchase or participating in online surveys. In those instances, you may decline to provide your Personal Information, but as a result you may not have access to those features. Snapnet also may retain electronic communications you send to our customer service representatives, webmasters or other representatives or other associates or service providers as a means to continually improve customer service. Snapnet web sites track information about visits to those sites. For example, statistics are compiled that show the daily requests received for particular files on a site, and what countries those requests come from. These aggregated statistics are used to customize our web sites to better meet your needs and may also be provided to others. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. If you decline to accept the cookie, it will also disable the web beacon. With both cookies and web beacons, the information collected and used is anonymous. The information collected does not contain your name, address, telephone number or email address. Some functionalities of the Snapnet sites may not function if you disable cookies and, in some instances, you may not be able to access or navigate our sites if cookies are disabled or limited.




Information We Share


We do not sell or otherwise disclose personal information about you, except as described in this Privacy Policy.

We may share the personal information we collect with our parent, affiliate and subsidiary companies, business partners, ad network vendors and their participants, and other third parties for the purposes described in this Privacy Policy, and to communicate with you about products and services, offers, events and promotions. We also may share personal information with our service providers who perform services on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We require any company with which we may share Personal Information to protect that data in a manner consistent with this Privacy Policy and to limit the use of such Personal Information to the performance of services for Snapnet.

We also may disclose information about you (i) if we are required to do so by law or legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell, merge or transfer all or a portion of our business or assets. Following such a sale, merger or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.





How Long We Retain Your Information

Snapnet will retain Personal Information concerning its customers, vendors, Site visitors, and others who do business with Snapnet so long as it is necessary to perform an ordinary or a common business function or to comply with a legal, regulatory, or contractual obligations.




Your Choices And Rights

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

Withdrawing Consent. If you have lawfully and appropriately consented to Snapnet processing your Personal Information, then you may withdraw that consent at any time. In some circumstances, withdrawing your consent to Snapnet's use or disclosure of your Personal Information will mean that you cannot take advantage of certain Snapnet offerings or site features.

Marketing Emails. You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in the marketing emails or by adjusting your email preferences using the online account you may establish on our sites.

Your California Privacy Rights. If you are a California resident, you may request that we provide to you (i) a list of the categories of Personal Information about you that Snapnet has disclosed to third parties for the third parties' direct marketing purposes during the calendar year preceding your request, (ii) the names and addresses of such third parties, and (iii) if the nature of the third parties' business cannot reasonably be determined from their names, examples of the products or services marketed, if known to Snapnet, sufficient to give you a reasonable indication of the nature of the third parties' business. To submit your request, please email info@snapnet.com.ng, with the subject line "California Privacy" and your request in the body of your email.

General Data Protection Regulation. If your Personal Information is protected under the European Union (EU), General Data Protection Regulation (GDPR) (2016/679), then you have the following rights (subject to certain exceptions) related to your Personal Information: to request access and rectification to, and erasure of, Personal Information (see below); to request a restriction on processing Personal Information; to receive Personal Information in a structured, commonly used and machine-readable format; to transfer Personal Information to another organization; to object to the processing of Personal Information; and, to not be subject to a decision that is based solely on automated processing, including profiling. You may also have the right to lodge a complaint with supervisory authorities in the EU to remedy or otherwise resolve matters or concerns related to the collection, use, processing, or retention of Personal Information.




Access And Correction

You may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information using the online account you may establish on our websites. In addition, if you believe other personal information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us as indicated in the "How to Contact Us" section of this Privacy Policy. If we deny an access request, we will notify you of the reasons for the denial.

We will honor any statutory right you might have to access, modify or erase your personal information. To request access and to find out whether any fees may apply, if permitted by applicable national laws, please contact us following the instructions in the "How to Contact Us" section below. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws but will give you reasons if we do so.




Children's Privacy

Children under 13 years of age are strictly prohibited from visiting or using the website and Snapnet does not knowingly collect any Personal Information (such as name, address and telephone number) from children under 13 years of age through its web site. However, if the parent or guardian of a child under 13 believes that their child has provided us with personally identifiable information, that parent or guardian should contact us if they want this information deleted from our systems. If Snapnet obtains knowledge that it has personally identifiable information about a child under 13 in retrievable form in its files we will delete that information from our existing files. In addition, anyone under 18 years of age should seek their parent's or guardian's permission prior to using or disclosing any Personal Information on this site.




Updates To This Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Policy and indicate at the bottom of the notice when it was most recently updated.




How To Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at info@snapnet.com.ng. You also may write to us at:

Snapnet, Ltd.
Attn: Privacy Manager
1b, Abayomi Shonuga Crescent,
Lekki Phase 1,
Lagos State, Nigeria.

Last Modified: May 30, 2018