a. Personal Information: We may collect personal information that you voluntarily provide to us, such as your name and email address when you register for an account or communicate with us.

b. Usage Information: We may collect non-personal information about how you use the Website and App, including your device information and IP address.

c. Cookies and Similar Technologies: We may use cookies and similar technologies to collect information about your browsing activities on the Website and App.

Any of the information we collect from you may be used in one of the following ways: To personalize your experience (your information helps us to better respond to your individual needs) To improve our website/app (we continually strive to improve our website/app offerings based on the information and feedback we receive from you) To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs) To process transactions To administer a contest, promotion, survey or other site feature To send periodic emails We use aggregated information to analyze the effectiveness of the website and App, to improve the same, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in the App and website, and may share aggregated information with third parties. We may collect aggregated information through the features of the software that supports the App, through cookies, and through other means described in this Policy. To enable us to better understand the characteristics of our users and/or to provide services tailored to your needs, we may combine your personal information with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically collected, non-individually identifiable information with your personal information, the resulting combination will be treated as personal information under this Policy. The processing or use of your information for the reasons specified above is legally permissible under Section 2.1 and 2.2 of Nigerian Data Protection Regulation (NDPR) a nd necessary for the purposes of the legitimate interests pursued by NoteHalo.

We collect and use your personal data: to process your membership application or renewal; to verify your identity; for direct marketing purposes to send you information, newsletters and other materials about us and event invitations both in print and in electronic form (see “Direct marketing” below); to collate data and prepare reports on our operations; to process billing and payment, to determine amounts outstanding, and, if necessary, to collect outstanding payments; to liaise with Government departments and agencies to communicate with you regarding your membership and assist with your queries; and to make such disclosures as required by applicable laws. While the supply of your Personal Data is voluntary, if you choose not to provide your Personal Data to us, we may not be able to provide you with the information or our services you require.

NoteHalo will collect End User Data necessary to provide the NoteHalo services to our customers. End users may voluntarily provide us with information they have made available on social media websites. If you provide us with any such information, we may collect publicly available information from the social media websites you have indicated. Y ou can control how much of your information social media websites make public by visiting these websites and changing your privacy settings .

We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you. W e may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest. We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the website/app, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the website/app. We will likely share your personal information, and possibly some non-personal information, with these third parties to enable them to perform these services for us and for you. We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website/app in a shared location, and type of the device used to visit the website/app. They may aggregate information about our advertising and what you see on the website/app and then provide auditing, research and reporting for us and our advertisers. We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

NoteHalo will collect personal information that you submit to us. We may also receive personal information about you from third parties as described above.

We keep your information only so long as we need it to provide NoteHalo to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. We cannot, however, ensure or warrant the absolute security of any information you transmit to NoteHalo or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

Building a tool for inspiring you daily means we have a responsibility to keep your data safe. We do not sell our users’ names or phone numbers to third parties because it is against our ethics. So that our users are able to use our app for free, we work with advertising partners such as Google and others listed in our app and provide trusted partners with caller ID services. Period.

Where Personal Information is to be transferred to a country outside Nigeria, NoteHalo shall put adequate measures in place to ensure the security of such Personal Information. In particular, NoteHalo shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) White List of Countries with adequate data protection laws. Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation. NoteHalo will therefore only transfer Personal Information out of Nigeria on one of the following conditions: The consent of the Data Subject has been obtained; The transfer is necessary for the performance of a contract between NoteHalo and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request; The transfer is necessary to conclude a contract between NoteHalo and a third party in the interest of the Data Subject; The transfer is necessary for reason of public interest; The transfer is for the establishment, exercise or defense of legal claims; The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent. NoteHalo will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request by NoteHalo.

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

Under the NDPR, you have the right to request access to, correct or delete any personal information that you have provided to us. You may send us an email to effect any of these. Please note that we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. You also have to right to data portability. In addition, you may also lodge a complaint with NITD NoteHalo’s Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent l oss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

You can object to the processing of your personal information, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

You can request for the transfer of your personal information to you or to a third party. We will provide you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Please note that this request may also attract an administrative fee

You can withdraw your consent anytime where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Through your use of the Site or Services, You agree that the laws of the Federal Republic of Nigeria shall govern any matter or dispute relating to or arising out of this Agreement. The courts in Nigeria shall have jurisdiction over all matters arising from the use of the Website portal or the Services. By using NoteHalo or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

By using our website/app, registering an account, or making a purchase, you hereby consent to our Privacy Policy and agree to its terms.

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by NoteHalo. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

NoteHalo uses "Cookies" to identify the areas of our website that you have visited. We use Cookies to enhance the performance and functionality of our website/app but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the website/app as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.

Wherever you're located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware t hat you may also lose some saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser's help menu for more information.

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.

We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third- Party Services").You acknowledge and agree that NoteHalo shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. NoteHalo does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services. Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.

You can set your mobile device to refuse all or some mobile cookies, or to alert you when cookies are being sent by logging into the App and visiting your account profile page. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.