TYEN strives for transparency and trust when it comes to preserving your privacy, and we aim to clearly define how we process your information. It’s essential to us that you enjoy accessing the contents and services on our website(s) without jeopardizing your privacy in any way. This policy outlines how we use different types of personal information and the reasons for doing so. You have the right to access, change, or delete your personal information at any time.

BY USING, INSTALLING, REGISTERING TO OR OTHERWISE ACCESSING ANY OF OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND ISSUE AN EXPRESS AND INFORMED PERMISSION TO THE COLLECTION, USE, AND PROCESSING OF YOUR PERSONAL DATA. PLEASE, IF YOU DISAGREE TO THIS PRIVACY POLICY, KINDLY DO NOT VISIT, INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS ANY OF OUR SERVICES.

THE INFORMATION WE MAY COLLECT FROM YOU

We collect information from or about you, depending on the nature of your interaction with our Services. Based on your use of our Services, information gathered may include: name, gender, email address, health information, physical address, birth date, and device or browser information. Below are detailed explanations of the information we collect from you:

Signing Up/Registering for our Services: By visiting or using our Services, we may obtain your name, email address, gender, health information, physical address, birth date, and device or browser information when you decide to sign up for newsletters or create an account for any of our Services.

Emails and Using our Website(s): We collect details of your visits to our Website (such as visited pages, your IP address, browser details) and your interactions with any of our emails sent to you. This information may include browser type, Internet service provider (ISP), Internet protocol (IP) addresses, the files viewed on our site (such as HTML pages, media, etc.), referring/exit pages, date/time stamp, operating system and/or clickstream data to analyze trends in the aggregate and record our analytics.

Transactions with our Services: When you submit an opinion or comment through our services, contact us, or request for more information in regards to a product or service(s), you will be asked to input your personal details in order to respond to you or to fulfill your request.

Social Media and Sharing: If you post a comment or share an article or other content with a contact/friend, we will collect their name(s). This information may be used for advertising purposes. Comments will be occasionally anonymized and employed in marketing materials.

Promotions: TYEN may, from time to time, offer promotions on our Services. Such promotions may require your name and contact information in order for you to be registered.

Device Information: We receive information about the phones, computers, or other devices from where you install or access our Services, depending on your granted permissions. We may combine the information we collect from your separate devices, which helps us provide regular Services across your devices. This information may include: hardware version, attributes such as the operating system, battery and signal strength, device settings, file/software names and types, and device identifiers; Bluetooth, or Wi-Fi signals; connection information, such as your mobile operator name or ISP, device locations, including specific geographic locations, such as through GPS, browser type, mobile phone number, mobile ad id, language and time zone, and IP address.

App Use: We may additionally obtain your date of birth, health information (diagnosis: when you were diagnosed, what medications you’re taking), gender, zip/city marital status, when you install, sign up for and use our App(s). When you download and use our Apps, additional privacy terms relevant to that specific App may be presented to you, and we systematically collect information on the type of device you use and version of the operating system. We use the above information to respond to your questions and concerns, send you newsletters, respond to customer service requests, etc.

Other Sources: We receive information on and off our Services from third-party partners, both about you and your activities, such as data from a partner when we team up to offer services or from an advertiser about your encounter or interactions with them. We may add this data to the information we have already collected from you in order to further improve the products and services we render.

COOKIES AND TRACKING TECHNOLOGIES

TYEN and its partners use cookies or similar technologies to analyze trends, group demographic information of our user base and track users’ movements around the website. You can regulate the use of cookies at the individual browser level, but if you wish to disable cookies, it may restrict your usage of some features or functions on our website or service. Unless you modify your browser setting to refuse cookies, our system will issue cookies when you land on our Websites. Some Internet browsers have an additional ‘do not track’ feature that lets you tell websites that you prefer your online activities not to be tracked. Currently, as we are trying to provide you with a personalized experience, we, therefore, do not respond to ‘do not track’ signals.

We make use of session cookies (they expire at the end of a browser session when a user exits the browser) and persistent Cookies, which remain on your hard drive till you clear them or they expire. A persistent cookie remains on your browser for how long that the visited website has programmed it to last, or be stored for use.

We use Cookies for different purposes, including personalizing content, targeting advertisements, and tracking your consent for various services.

To the degree approved by applicable law and with your consent, we may authorize third parties to manage user Personal Information over time or across third-party websites, and we may allow third parties to passively gather Personal Information on our Websites for behavioral advertising objectives, including: Retargeting: To provide you with more customized web experience and to present you with information of interest, our advertising partners may seek to use their observed behavior on our Website to deliver targeted ads when you are on another website.

From time-to-time, we send you push notifications in order to update you with promotions that we may be running or about any of our events. To ensure you receive precise notifications, we will need certain information collected about your device, such as operating system and user identification information.

HOW DO WE USE YOUR INFORMATION?

We use your information with your consent for the reasons that you provide such information. And for the purposes outlined below:

To provide and improve our Services: We use the information we have to deliver and enhance our services, including personalized content, features, and making recommendations for you on our Services when necessary.

Marketing: We use the gathered information to enhance our advertising systems, so we can show you suitable ads and measure their effectiveness and reach. For other marketing and market research purposes and to learn more about our users, we may use your Personal Information. By applicable laws, we will only contact you for direct marketing objectives. You may opt-out your Personal Information from being used for market research, marketing, or direct marketing objectives at any time by sending a rights request message to us, using the link herein.

Transactions: We utilize your Personal Information in the processing of your transactions, sending you confirmations, responding to your requests, and for other related communications.

Retargeting: Your information collected allows us and/or third parties to deliver interest-based ads on our sites, third-party sites, or affiliated sites. Our retargeting activities follow the NAI code of conduct.

Analytics: We may retain full details of your visits to our platform(s) and also store your electronic communications with emails we send to you (“Usage Data”) under a pseudonym (i.e., under an ID number, instead of your name), including the pages you visited and services you used in the process. We use such ‘Usage Data’ to help us learn more about our users’ preferences, to be able to tailor our Website according to your preference and interests, to help us improve our site design, products and services, address problems, analyze trends/statistics and to present content in most transparent and friendly manner for you.

Communicate with you: To send you marketing communications about our Services and update you on our policies and terms, we use your information. We also use your information when responding to you when you reach out to us.

Other Reasons: We may collect and use Personal Information for any purpose in relation to the purposes above.

HOW AND WHEN IS YOUR INFORMATION SHARED OR DISCLOSED?

To improve our Services: We may disclose your information with third parties who render services on our behalf to assist with our business activities, such as email service providers, ad technology providers, data analyzers and business intelligence providers. These companies are allowed to use your personal information solely when providing these services to us. These third parties currently may include: Google, Index Exchange, LunaMetrics, Moat, Nexage, Oath, OpenX, PageFair, PX, Rubicon, Acxiom, Adbridg, Akamai, Sailthru, SendBird DBA, Teads, The TradeDesk, Amazon, AppNexus, Criteo, District M, Facebook, Yieldbot, TripleLift.

Third-Party Marketing: We provide advertisers with reports of their ads performance and kind of people seeing their ads, but we don’t share information that personally identifies you (such as your name or email address that can serve as a means of contact to you) unless you permit us. In the bid to provide you with useful information about our services, we may request to share your information (such as your email address) with third-party business partners. Please have it in mind that before we share your information, you will receive a one-time notification of the proposed sharing and we will obtain your consent, or opt-in, to such sharing. You may decide not to opt-in; until you do, we will never share your information for these purposes.

Third-Party Services: When you extend your interaction on our services with a third-party advertiser, the content creator or advertiser can obtain the information you share with them, as well as the information needed to complete the transaction, which may include your contact details and medical information.

Asset Sale: In the event of a transfer of all or some of our assets to a third party, we may transfer all your Personal Information along to them, provided that the third party accepts to adhere to terms similar to those of our Privacy Policy. Nevertheless, we shall provide you with an opportunity to reject the transfer of your Personal Information in such cases, where required by applicable law.

Legal Requirements: We may access, conserve, and share your provided information in response to a legal request if the law requires us to do so. We may also access, store, and share your information when it is necessary to: detect, address, and prevent fraud or any other related illegal activities for investigations purposes. The essence of this is to protect you and us from any form of harm and also to honor legal requirements. Hence, we may disclose collective information about website users without restriction.

ONLINE MARKETING

As explained above, we may use or disclose, when appropriate, your Personal Information for marketing and market research purposes. This will enable us to discover more about our users, offers, conversion rates, and learn how best to improve our Services. Only when required by applicable laws will we contact you for direct marketing purposes. You may wish to opt-out anytime for our use of your Personal Information for marketing, market research, or direct marketing purposes as outlined below:

YOUR RIGHTS: ACCESS TO PERSONAL INFORMATION, CORRECTION, RETENTION, DELETION, AND CHOICE

U.S. Website Users

Opting-Out of Marketing and market research Communications:

In respect to Personal Information that you have given to us under this Privacy Policy, you may opt-out of use for market research and marketing, such as communication from us about our products and promotions or from we sharing with select third parties your Personal Information for their direct marketing schemes.

You may opt-out by emailing [email protected] or using the rights request form. If you do not initially opt-out upon account creation, your opt-out choices may take (30) days for full effectiveness. We may also require information from you to verify your request, when you make a request, like your already-provided email address.

Unless prohibited by applicable law, your opt-out preference does not apply to (i) any communication which is not promotional in nature, (ii) sharing and use by us of your Personal Information with service providers we use to enhance your experience on our Websites, and (iii) to enable us to present you with more personalized advertising across the web.

Your California Privacy Rights

California law demands certain businesses to reply to requests from California residents inquiring about the reveal of Personal Information to third-party for marketing programs. Alternatively, such businesses may utilize a policy of not disclosing Personal Information to third parties for marketing plans if a California resident opts-out.

TYEN provides you with a cost-free means to opt-out of such sharing. If you do not want TYEN to disclose information to other companies for their marketing purposes, please follow the opt-out steps stated above.

You may also instruct us to no longer share your personal information with third parties by using the rights request form or emailing [email protected]. Kindly include your personal details you have provided to us for verification (Including your name and physical address(es) and email addresses) to verify your request.

California’s Digital Online Eraser Law

The California Digital Online Eraser Law (California Senate Bill 568) grants users, under the age of 18, with the right to request for the removal of content/information they have posted publicly on any Service. Please be cautioned that any information you post to a message board, bulletin board, community, chat room, or other online forum is publicly viewable and accessible. We firmly recommend that all users avoid posting personal and sensitive information anywhere and anytime. To request removal of information or content under this section, please use the rights request form or email [email protected].

Please be informed that even though we may comply with your request for the removal of this information or content from public sight, we cannot guarantee comprehensive or complete removal. However, we may retain full copies of the information or content you have previously shared on our server; we are not required to remove your posted information or content if we are required by law to retain it or if it has been rendered anonymous. Additionally, we do not have authority over third parties (i.e., other users) who may have copied or reposted this information.

Non-U.S. Website Users

Rights Requests:

Upon request, TYEN will provide you with information about whether we hold any of your personal information, or process on behalf of a third party. To request this information, please contact us by sending a request mail to [email protected], or using the rights request form. Please note that, upon your request, we may ask you for some of your personal information to verify the request (this information may include your name and email address(es) or any other necessary details that may have provided to us earlier).

You may also access, correct, or request removal of your personal information by contacting us through the contact options listed above. We will respond to these requests within the shortest possible time.

Subject to applicable law, we may hold your information for as long as your account is active on our platform or as needed to provide you services, resolve disputes, comply with our legal obligations and enforce our irrevocable agreement(s).

In the process to serve you better, we may be sending you newsletters upon your sign-up for it or other communications from us. If you would like to terminate this subscription, you may choose to update your email preferences by using the “Unsubscribe” link found beneath the emails we send to you on a regular.

Your Choice

We also team up with third parties and partners to display advertising on our website or to handle our advertising on other sites. Our third-party partners may use, to provide you advertising based on your preference and internet activities, cookies, or similar technologies, your Personal Information. Kindly visit http://pereferences-mgr.truste.com if you prefer to opt-out of interest-based advertising. If you are in the European Union region, visit http://www.youronlinechoices.eu. Please be aware that generic ads may still be promoted to you, not based, however, on your Personal Information.

Your Security

The security of your personal information is valuable to us. We follow generally accepted measures to protect the personal information submitted to us, both when transmitted and once it is obtained, and take various precautions to guard data from loss and misuse. If you have inquiries about the protection of your personal information, you can contact us at [email protected].

Children’s Privacy

Personal Information about children under the age of 18 are not intentionally collected or maintained on our platform(s). We request that our website(s) and services could only be used by a child under the age of 18 only for educational purposes or other relevant purpose, with full belief that such approval is coming from the child’s parents/guardians. In the event that a child under the age of 18 sends us their personal information or makes use of our services, we will remove them from our record/database, unless otherwise the registration and management of such underage child’s account is been handled or approved by the parents/guardians.

Also, to parents/guardians; if you think your child under the stipulated age is sharing their personal information with us, and you wish to remove them, feel free to send an email to [email protected]. We shall respond as swiftly as possible. Please note that we shall request for verification of ownership of the child and age before we will honor your request.

WEBSITE LOCATION, TRANSFERS & PROCESSING

The site is operated in Nigeria by the NGO, The Young Creative Thinkers Initiative (RC No.: 127873), and personal information will be primarily stored in Nigeria. By supplying personal information to us, to the greatest extent permitted by applicable law, you confirm that we collect, maintain, process and convey such information in and to Nigeria and other countries and territories, Pursuant to Nigeria laws or such other jurisdictions, which may provide lesser privacy protection than the European Economic Area countries. And to the largest extent permitted by applicable law, you recognize that your information may thus be subject to Nigeria and other foreign laws, and accessible to only Nigeria Governments, courts, law enforcement, and Regulatory Agencies. Because TYEN CLUB is located in Nigeria, these data transfers to Nigeria Government are essential to provide the services to you as outlined in our TERMS OF SERVICE and also to operate our Platform(s) in general. When relevant, we will obtain your consent for these data transfers as applicable by law.

Changes to this Policy

This privacy policy is bound to be updated to include changes we may have made to our information practices. You would be notified, by means of an email (sent to the e-mail address inputted in your account) or by a prior notice on our platforms, before it takes effect. We urge you to regularly review this page for the newest information on our privacy practices.

LAST UPDATED: 13TH FEBRUARY, 2020.