Privacy Policy

2. Personal data we collect

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We collect the following personal data about you:

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• Registrations: The personal details you provide when creating an Account, ​such as your email address, name, phone number, job title, name of company, year of birth, identification number, payment and billing details or other information ​that we require for the purpose of recording and processing your campaigns.  For further details please also refer to the section below headed “Payment Information”.
• Customer Transaction: The personal details you provide when you’re registering your account. These transactions typically include your full name, address, email address; business address and phone number; gender, approximate age, industry, career level, approximate budget spend; information about your work and other information that you elect to provide to support your application. such as your first and last name, email address, billing and payment information (for further details please also refer to the section below headed “Payment Information”).
• Other Information: Personal details you choose to give when corresponding with us by phone, intercom or e-mail, participating in user/customer/member surveys or otherwise visiting and interacting with this ​Application or any other ​Applications we operate, and personal data that you provide to us when you visit ​our Application.

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By consenting to the Wowzi Privacy Policy;

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• I hereby grant Wowzi consent to collect my name, official Government ID Number (ID Number) and photo image. I understand that Wowzi may share this information with a 3rd party, Smile Identity Inc in order to validate it against a Government source. I also understand that Smile Identity Inc may use my ID Number to collect the following additional data on me: Full Name; Date of Birth; ID Number; Image; Address; Phone Number; Gender; Government ID Expiry Date; and Or other additional information associated with my ID Number that the Issuing Authority may provide.
• I understand that this data is being used to confirm my identity. I understand that this data may be processed or stored outside of the borders of Nigeria, Kenya, Ghana, South Africa, etc and I hereby consent to this. I am aware that if I wish to change my preferences, request that my data be edited or deleted or withdraw my consent at any time I must contact Wowzi.

3. Automatically collected personal data

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• Log Data: When you visit our Application, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Application. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Application), browser type and settings, the date and time of your request.
• Our Application uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Application and allows us to improve its features.

4.  Facial recognition data collection and use

As part of our commitment to providing an open and secure creator commerce platform, we have integrated systems for user identity verification where Wowzi shall utilize the services of  Smile Identification (SmileID). 

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Smile ID is Wowzi’s  a third-party service provider that has developed software to assist companies in digital identity verification, fraud detection, anti-money laundering and providing KYC compliance solutions. 

We have integrated the said software onto the platform and require all users on the platform to provide the requisite data to facilitate these verification processes.

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Consent

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Since this is an additional means of processing your data through a third party that you have not necessarily contracted with, we require your express consent for this manner of processing. While undertaking the KYC process on our creator mobile app, you are at liberty to provide or withhold your consent, keeping in mind the mandatory nature of the process for users on the platform.

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Mandatory Requirement

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The processing of facial recognition data is a mandatory requirement for all users on the platform.

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What type of data will be collected?

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Smile ID shall  collect the following information for KYC and user verification purposes:

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• Facial photographs
• Full name
• Date of birth
• Identification number (e.g., national ID, passport number)
• Relevant Revenue Authority Personal Identification Number 
• Other personal information as may be requested from you for identity verification from time to time

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These details are mandatory requirements for onboarding. Users missing particular information at the time of the integration of the software will be contacted for provision of the same. This data collection is essential for our identity verification process, ensuring compliance with legal and regulatory requirements.

Users must ensure that the data provided is authentic and accurate. Every user shall be required to take all reasonable steps to ensure that any inaccurate data is erased or rectified without delay for example by updating any changes in the basic information collected as above.

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What is the purpose and Legal Basis of Data Collection?

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The identity verification data is collected and processed for:

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• User identity verification
• Compliance with legal and regulatory requirements on for example anti-money laundry and identity theft prevention

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Performance of contractual obligations with brand companies and other Wowzi partners. The data collected shall be used for the sole purpose of identity verification and shall not be processed any further in a manner incompatible with these purposes. Should the purpose of processing the said change or morph, we shall actively seek your consent on any further processing activities.

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Data Storage and Security

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Your data is securely stored and protected using industry-standard security measures, including encryption. The data is stored by SmileID, who adheres to stringent security protocols to protect your information. Wowzi has limited access to this data to monitor processing activities, ensuring compliance and security.

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Data Sharing

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Your facial recognition data is shared with SmileID for the sole purpose of identity verification. We do not share your data with any other third parties unless required by law or after having sought express consent for the same from you.

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For how long will my data be retained by Smile ID?

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Your facial recognition data is retained only as long as necessary for the purposes outlined or as required by law. The retention of the data will subsist for the period in which the data subject maintains an account on the platform. Beyond this, specific retention periods are determined based on regulatory requirements and business needs.

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Once an account is deleted and the legal and regulatory timelines for retention of the said data have lapsed we shall update Smile ID of this fact for permanent eraser of the data identity verification data we have collected from you.

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Is my data safe?

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Your data is stored by SmileID, a third-party service provider. The data is stored securely with safeguards against breaches, including encryption and stringent access controls. Wowzi has unlimited access to the data to ensure proper monitoring of data processing activities in line with its obligations as a data controller in this instance.

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What rights do I have as a user?

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Along with the right to be informed of the nature and purpose of processing the identity verification data, the following rights also apply with regard to the data collection and processing: You have the following rights concerning your facial recognition data:

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• Right to access: You can request access to your data.
• Right to rectification: You can request correction of false and/or misleading data.
• Right to erasure: You can request deletion of false and/or misleading data.
• Right to restrict processing: You can request limitations on how your data is processed.
• Right to data portability: You can request your data in a portable format.
• Right to object: You can object to the processing of all or part of identity verification data.

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Contact Information

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If you have any questions or concerns about your facial recognition data, please contact us at mailto:support@wowzi.co.

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5. How we use your personal data

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We use your personal data in the following ways:

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• To acknowledge and confirm receipt of your Social Media Use “Wowzi Account” application (and where necessary put you on our waiting list). Such use of your data is necessary in order for review to be undertaken on the application and a link created with the respective advertiser.
• To contact you in connection with user/customer/member surveys and use any information you choose to submit in response, provided that you gave us your consent to be contacted in this way at the time you provided us with the personal data.
• From time to time, we may organize contests and other promotions. If you share information with us directly or through one of our third party service providers, we may use the email address you provided in order to notify you of the results.
• If you choose to subscribe (opt-in) to one of our various newsletters, we will send our periodic newsletter to the email address you provided us. Members can opt-out of our newsletters at any time by clicking the “Unsubscribe” link that is present on every email at the very bottom of the newsletter.
• Wowzi and our affiliated businesses, “Wowzi” in particular, may provide you, or permit selected third party service providers to provide you with information about goods or services, events and other promotions we feel may interest you as a member, applicant or customer. We (or such third party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.
• We may use your personal data for other purposes which you have consented to at the time of providing your data.
• As necessary for certain legitimate business interests, which include the following:

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1. where we are asked to deal with any inquiries or complaints you make.
2. to administer our Application, to better understand how customers interact with our Applications and ensure that our Application is presented in the most effective manner for you and for your computer/device.
3. to conduct analytics to inform our marketing strategy and enable us to enhance and personalize the experience we offer to our members and our communications, including by creating customer or member profiles to enable personalized direct marketing communications.
4. If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.

1. to share personal data among our affiliated businesses for administrative purposes, for providing customer or member services and in relation to our sales and marketing activities.

1. we may anonymize, aggregate and de-identify the data that we collect and use such anonymized, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behavior.

1. for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Application, network and information systems secure.

1. to (a) comply with legal obligations, (b) respond to requests from competent authorities; enforce our Terms of Use; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforcing or defending legal rights, or preventing damage.

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As used in this Privacy Policy, “legitimate interests” means the interests of Wowzi and our affiliated businesses, in conducting and managing our organization. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under the data protection laws.

6. Disclosure of your information

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We share your personal data with third parties in the following situations:

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• Service Providers: Wowzi, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed “Payment Information”), (ii) credit reference agencies to protect against possible fraud, (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide users services and other goods/services available on this Application or to members, (iv) web analytics providers, (v) providers of digital advertising services and (vi) providers of, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
• Wowzi Affiliated Businesses: We operate on a global scale. In order to provide the services you request from us, our affiliated businesses may access and process the information which we collect from you for the purposes described above, including to offer products and services to you. Our affiliated businesses will only use your data for the purposes for which we originally collected it.
• Business Transfers: if we sell our business or our company assets are acquired by a third party, personal data held by us about our applicants, members, customers may be one of the transferred assets.
• Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms of Use or other applicable contract terms that you are subject to or (iii) to protect us, our members, applicants, customers, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organizations.

7. Payment information

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• Any credit/debit card payments and other payments you make through our Application will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.
• We may arrange that card or payment data you submit in support of a member or customer transaction fee is stored for the purpose of processing your member or customer transaction fees.
• You may choose to opt out of our third party payment providers holding your card or payment data although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee or for the purpose of making any future purchases.

8. Personal data transfers

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• Your personal data may be transferred to and stored in countries other than the country in which the information was originally collected, including countries and other destinations outside the Republic of Kenya to our service providers and affiliated businesses for the purposes described above.
• Where we transfer your personal data to countries outside of the Republic of Kenya we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law.

9. Security

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• Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Application, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or log-in details with anyone else.
• Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organizational security measures to protect the personal data that you submit to us against unauthorized/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

10. Personal data retention

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• We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain membership records for six years after expiration or termination of your membership. We retain information submitted through the Application and the other Applications we operate for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.
• To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means.
• Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

11. Your personal data protection rights

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Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:

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• Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a digital copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional print copies, we may need to charge a reasonable fee.
• Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
• Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your personal data, and we will do so:

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1. If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing or

1. If we are processing your personal data for direct marketing.

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• Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.

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If you wish to exercise any of these rights please contact us as described in the

“Contact” section below. We may also need to ask you for further information to verify

your identity before we can respond to any request.

12. Deleting profile details

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• If you would like to delete your account or profile, please send us an email from the phone number that is associated with your account to support@wowzi.co. Please let us know your username in that email, so that we may complete your request accurately.
• You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our servers. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Profile may exist in a non-erasable form that may be difficult or impossible for us to locate.
• In addition, we have the right to delete any account at any time if required to do so by process of law, or if necessary in order to investigate fraud, a violation of our Terms of Use or in connection with any harm being caused to a third party or their rights.

13. Contact

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Questions, comments or requests regarding this Privacy Policy should be addressed to support@wowzi.co.

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If you would like to delete your account or profile, please send us an email from the phone number that is associated with your Membership account to support@wowzi.co. Please let us know your username in that email, so that we may complete your request accurately.

14. Changes to our privacy policy

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Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.