AirSave Enterprises’ privacy policy is made in compliance with the Nigeria Data Protection Regulation (NDPR) Legislation (2019) and Nigeria Data Protection Act (2023)
These legislations touch on how personal information or data is processed, the rights of data subjects, requirement of consent for collecting and processing data, international data transfers and data compliance officers among others.
‘Personal information or data’ means information about an identified individual, or an individual who is reasonably identifiable. AirSave Enterprises’ Privacy Policy applies to personal information collected and/or held by AirSave Enterprises on the database of the website www.holdingbrief.com.
We may review this policy and update it from time to time.
The types of personal information we collect and hold
We collect personal information about our users in order to provide our services, products and customer support. Our services, products and customer support are provided through many platforms including but not limited to: websites, phone apps, email, and telephone. The specific platform service, product and or support you interact with may affect the personal data we collect.
Not all information requested, collected, and processed by us is “Personal Information” as it does not identify you as a specific natural person. This will include majority of “User Generated Content” that you provide us with the intention of sharing with other users. Such “Non-Personal Information” is not covered by this privacy policy. However, as non-personal information may be used in aggregate or be linked with existing personal information; when in this form it will be treated as personal information. As such, this privacy policy will list both types of information for the sake of transparency.
In some situation users may volunteer us personal information without us asking for it, or through means not intended for the collection of particular types of information. Whilst we may take reasonable steps to protect this data, the information provided will not be governed by this privacy policy.
In some situations users may provide us personal information over platforms that are outside our control; for example through social media or forums. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy.
How we collect personal information
Information that you specifically give us
While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, online chat systems, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.
We may request, collect, or process the following information:
Account Details – username, password, profile picture.
Contact Details – email address, phone number and or whatsapp number.
Job Location Details – physical address, billing address, timezone.
Identity Details – full name, proof of identity (e.g. drivers licence, passport), proof of address (e.g. utility bill), photograph of the user.
Financial Information – credit card details, wire transfer details, payment processor details (e.g. pay stack, flutter wave, stripe, PayPal) tax numbers.
User Generated Content – project / job descriptions and attachments, user profiles, user reviews, user messages etc.
Information that we collect from others
Users can give permission for us to connect to their account on other platforms to collect personal information. This includes but is not limited to Facebook, LinkedIn, and Google. Information collected will be governed by this Privacy Policy. Users can stop us from collecting data from other platforms by removing our access on the other platform or by contacting our support team.
Users have the ability to invite non-users on other platforms to our platform by invitation any information collected that way will be stored by us to contact the non-user and to prevent abuse of the invite systems.
Your payment provider may transmit information about the payment that we may collect or process.
In some situations, personal information of users may be collected from public sources.
We may collect or process the following information
Basic Details – username, profile picture.
Contact Details – email address, phone number.
Job Location Details – Physical Address, billing address, time zone.
Financial Information – payment account details (e.g. PayPal email address and physical address), and wire transfer details.
List of contacts – email provider address book.
User Generated Content – user profile.
Information we collect as you use our service
We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button.
In order to deliver certain products or services we may passively collect your GPS coordinates, where available from your device. Most modern devices such as smartphones will display a permission request when our platform requests this data.
When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.
We may collect or process the following information
Metadata – IP address, computer and connection information, referring web page, standard web log information, language settings, timezone, etc.
Device Information – device identifier, device type, device plugins, hardware capabilities, etc.
Job Location – GPS position.
Actions – pages viewed, buttons clicked, time spent viewing, search keywords, etc.
Links to other sites
On our website, you may encounter links to third party websites or platforms. These links may be from us, or they may appear as content generated by other users. These linked sites are not under our control and thus we are not responsible for their actions. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.
How we use personal information
The information we request, collect, and process is primarily used to provide users with our service. More specifically, we may use your personal information for the following purposes:
To provide you the service or product we provide;
To facilitate the creation of the User account of your choosing;
To provide technical or other support service to you;
To answer enquiries about our services, or to respond to a complaint;
To promote our other programs, products or services that may be of interest to you;
To allow for debugging, testing and otherwise operate our platforms;
To conduct data analysis, research and otherwise build and improve our platforms;
To comply with legal and regulatory obligations;
If otherwise permitted or required by law; or
For other purposes with your consent, unless you withdraw your consent for these purposes.
The ‘grounds’ on which we will use personal information of our users are inter-alia
When a user willingly provides us with personal information from where we infer consent;
When necessary for the performance of a service contract of which the user is party thereof;
When Processing of same is necessary for compliance with our legal obligations;
When Processing of same is necessary in order to protect the vital interests of our users or of another natural person.
When Processing of same is done in pursuit of our legitimate interests, where these interests do not infringe on the rights of our users.
When we disclose personal information to third party service providers
When the personal information of users may be held, transmitted to or processed on our behalf outside Nigeria, including ‘in the cloud’, by third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
Our third party service providers include
Cloud hosting, storage, networking and related providers
SMS providers
Payment and banking providers
Marketing and analytics providers
Security providers
Third party applications
Through the holdingbrief API it is possible for users to grant third party applications access to their holdingbrief account. Depending on the permissions that are granted, these applications may be able to access some personal information or do actions on the users’ behalf. These third party applications are not controlled by us and will be governed by their own privacy policy. Users are responsible for blocking third party applications from accessing their data.
Other disclosures and transfers
We may also disclose your personal information to third parties for the following purposes
If necessary to provide the service or product you requested;
We receive court orders, subpoenas or other requests for information by law enforcement;
If otherwise permitted or required by law; or
For other purposes with your consent.
Accessing, correcting, or downloading your personal information
You have the right to request access to the personal information holdingbrief holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense or charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform please contact our Data Protection Officer (DPO).
You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support at holdingbrief@gmail.com or by clicking on the contact us form.
To contact our Data Protection Officer (DPO)
If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Data Protection Officer (DPO) as follows:
By Email at:
holdingbrief@gmail.com
While we endeavor to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Data Protection Officer, by email as above. We will acknowledge your formal complaint within 10 working days of receipt.
Airsave Enterprises reserves the right to make changes to this Privacy Policy at any time without notice to you, and such changes will uploaded on the website – holdingbrief.com