Nook Privacy Policy

1. Introduction

This Privacy Policy describes how Beedcom Interactive Services Limited, with its registered office at 294 Herbert Macaulay Way, Yaba, Lagos - Nigeria, owner of the Nook app (referred to as "Nook", "we", "our'', or "us"), collects, uses, and shares your personal information when you use our Applications. We are committed to creating a trustworthy online environment for our users and to the ethical collection, use, and protection of your personal information.

2. Information We Collect

Directly Provided Information: This includes data you submit during account creation, participation in polls, or any other interaction on our Applications. Examples include your name, phone number, and other voluntary submissions like your location and contact information: If granted permission, we may sync your mobile device's contact list. Types of Data Processed: This encompasses contact details, content data, usage specifics, and meta/communication data.Usage Data & IT Infrastructure: Data related to your interactions and the technology used during your sessions. Location Information including state/province, city, or zip code, as well as precise location data (but only if you voluntarily granted permission and permitted your mobile device to transmit location data). In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to your identity. For example, we use the information we collect about users to optimize our Services and understand their traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with information that identifies you. In that case, this Privacy Policy governs how we use that information. Additionally, if you have visited our mobile website or activated one of our mobile device applications, and if the settings on your location-aware device allow us to receive Location Information, we will collect that automatically. If we associate Location Information with other information that identifies you, this Privacy Policy governs how we would use that information, too.

3. Purpose of Data Utilization

Poll Creation & Participation: All polls on the platform undergo content moderation. This may involve sending notifications to your contacts. App Enhancement: Data helps refine our Applications and drive new feature development.Feedback, Communication, & Security: For improved communication, platform security, and better user experience.

4. Sharing and Retention of Data

We don’t sell or lease your personal data to third parties for marketing without clear consent. Situations where sharing might occur include Poll Participation: Your participation status may be disclosed to the poll creator. Data remains with us for the necessary duration, or as mandated by law.

5. Children's Privacy & Policy Changes

The Nook App isn’t designed for users below 13 years old. Unintended data collection from these users results in the immediate deletion of related accounts and data. We may periodically update this policy, with changes promptly displayed here. Continued use post-amendment signifies acceptance.

6. Legal Considerations & Jurisdictional Compliance

Our data processing stands on Contractual Obligations: (Art. 6 (1) p. 1 lit. b) DSGVO) - For contract fulfilment. Legitimate Interests: (Art. 6 (1) p. 1 lit. f) DSGVO) - Necessary processing given it doesn't infringe upon user rights. National Regulations: For German users, the BDSG, especially regarding employee data, is observed. This policy adheres to data protection laws in Germany, the U.K., the U.S., and Australia.

7. Security Measures

We take appropriate technical and organizational measures, including TLS encryption, to safeguard your data. This ensures data confidentiality, integrity, and availability, among others.

8. Data Transfer

Data may be shared with other entities like service providers. We ensure legal compliance and proper protection during such exchanges.

9. Data Processing in Third Countries

Data processing outside the EU/EEA follows legal requirements and ensures an appropriate data protection level.

10. Data Deletion

Data will be deleted as per legal requirements unless needed for specific lawful purposes.

11. Provision of the Online Offer and Web Hosting

User data is processed to provide online services, including collecting access data and log files. Data in log files are stored for a maximum of 30 days, after which they're deleted or anonymized unless needed for evidence in specific incidents.

12. Contact & Queries

For inquiries regarding this policy or data practices, connect with us at hello@beed.ng

U.S. Data Protection Compliance

Compliance with the California Consumer Privacy Act (CCPA):
If you are a resident of California, you are granted specific rights regarding access to your personal information under the CCPA.

To exercise your CCPA rights, please contact us at hello@beed.ng.

Protection of Contact Book and SMS Data

When you permit us to access your contact list or SMS, we use this data solely to facilitate the services of the Nook App, such as locating contacts and sending poll participation notifications. We don't sell or share your contact list or SMS data with third parties. If we ever decide to use your contact list or SMS data differently, we will seek your explicit consent first.

Data Security Measures in the U.S.

We are committed to the security of your data and have implemented rigorous security measures in compliance with U.S. data protection laws. Our infrastructure employs state-of-the-art encryption, firewalls, and regular security audits to protect against unauthorized access, use, or disclosure of your personal information.

U.S. Children's Online Privacy Protection Act (COPPA) Compliance

The Nook App complies with COPPA. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use the Nook App. If you are under 13, please do not send any information about yourself to us. If we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible.

Changes to the Policy

We may modify this Privacy Policy at any time. If we do, we will notify you by posting the changes on this page. Your continued use of the Nook App after any modification constitutes your acceptance of the updated Privacy Policy. This Privacy Policy is governed by the laws of Nigeria, Germany, the U.K., the U.S., and Australia, depending on the location of the user.

If you have any questions about this Privacy Policy, you can contact us at hello@beed.ng.

Types of data processed

Categories of affected persons

Processing purposes

Relevant legal bases

The following is an overview of the legal basis of the GDPR based on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

Contractual performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO)
Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request. Registered interests (Art. 6 (1) p. 1 lit. f) DSGVO) - Processing is necessary for the legitimate interests of the controller or a third party unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data. In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular concerning the establishment, implementation, or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures
We take appropriate technical and organizational measures by the legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk. The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, the input of, disclosure of, assurance of availability of, and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, and software as well as procedures following the principle of data protection, through technology design and data protection-friendly default settings.TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data. Data processing in third countries we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done following the legal requirements. Subject to express consent or contractually or legally required transfer, we only process or allow the processing of data in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Data deletion
The data processed by us will be deleted following the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person. Our data protection notices may also contain further details on the retention and deletion of data, which have priority for the respective processing operations.

Provision of the online offer and web hosting
We process the users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.

Further notes on processes, procedures and services

Contact and request management

Further notes on processing processes, procedures and services:

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification. If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.