1. Privacy

Switch Recycling Innovations. (“us,” “we,” “our”, or “Switch”) respects the privacy rights of our customers, visitors, and other users of our recycling information services (collectively, “Services”) provided through our website, web Mobile Application, and any Mobile Application software for any platform (iPhone, Android, etc.) that you may download (collectively, the “Software”). We created this Software privacy policy (“Privacy Policy”) to give you confidence as you use the Software and to demonstrate our commitment to protecting any personal information we hold.

Switch Recycling Innovations is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this Privacy Policy and trained our employees about our policies and practices.

This Privacy Policy is only applicable to the Software. Our website may contain links to other websites and/or may be integrated with other software created by third parties. Those sites or software components are not governed by this Privacy Policy. Similarly, our Software may be embedded in other third-party websites that are not administered by us, and those sites are not governed by this Privacy Policy. Your use of the Software is governed by this Privacy Policy and the Terms of Agreement.

2. Software Data Collected

We automatically track and collect the following categories of information when you use our Software: (1) IP (which stands for Internet Protocol) addresses; (2) domain servers; (3) types of computers Accessing the Software; (4) types of web browsers used to Switch the Software; (5) referring source which may have sent you to the Software; and (6) other information associated with the interaction between your browser and the Software (collectively, “Software Data”).

3. Personal Information Collected

We provide our Services through our Software. For you to Switch certain features of the Software, we require you to provide us with certain personal information that identifies you, or from which your identity could be deduced (“Personal Information”). Personal Information includes (1) Contact Data (such as your e-mail address and Switch password); (2) Demographic Data (such as your gender and your age); and (3) Location Data (such as your address or zip/postal code). If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information. If we did not collect and use your Personal Information, we could not provide you with our Services.

You may choose not to provide us with any Personal Information. In such an event, you can still Switch and use much of the Software; however, you will not be able to Switch and use those portions of the Software that require your Personal Information.

If you access any Services requiring a username and password, you are solely responsible for keeping such items strictly confidential.

4. Cookies

“Cookies” are computer files that are placed on your computer by a website. In these files, various pieces of information can be stored, from user identification and preferences to activities conducted while browsing the website. You may block cookies or delete cookies from your computer if you wish but must do so at your own cost and responsibility. If you do block or disable cookies, and you are accessing the Software through a website, then you may not have to Switch to the entire set of features of our Software.

Generally, we use “cookies” to customize your experience on our website and to store your password so you do not have to re-enter it each time you visit the website.

We do not link the information stored in these cookies directly to any of the Personal Information you submit while using the Software.

5. Storage of Information

We store all Software Data and review postings indefinitely, even after they are deleted, and may retain such information elsewhere. We store all Personal Information until you request that we amend or delete it, in which case we may still end up retaining some of that information for the reasons described in Section 10 below.

6. Personal Information Protection and Electronic Documents Act

From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the other local laws for the Protection of Personal Information it incorporates. PIPEDA gives you rights concerning the privacy of your personal information. If you are located outside of Nigeria, you may have local laws which protect the collection and use of your personal information in your Country.

7. Switch’s Use of Your Information

We may use your Contact Data to send you information about Switch or our products or Services or to contact you when required, including to advise you about changes to your recycling information. We may use your Personal Information to customize your experience on the Software, in e-mails, and other communications, displaying content that we think is appropriate for you. You may unsubscribe from receiving further emails from us at any time by sending an email to support@switchrecycling.com with the word “Unsubscribe” in the subject line.

8. Information Sharing

We share certain categories of information we collect from you in the ways described in this Privacy Policy. We may share Demographic Data and Location Data with other third parties only on an aggregate (i.e., non-personally identifiable) basis.

We may occasionally provide the Services in partnership with your local government. By using the Software and Services and providing us with Personal Information, you consent to our sharing of Demographic Data and Location Data with your local government.

We also share Personal Information with our business partners who assist us by performing core services related to our operation of the Software. Those business partners shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Personal Information to carry out their specific business obligations to Switch and to provide your requested services. We may also transfer information about you to third parties in connection with a merger, sale or acquisition by or of Switch.

We may share your Contact Data, Demographic Data, and Location Data with third-party service providers to facilitate the seamless integration of different software components. For example, we may share your username and password information with such third-party software providers to avoid the need for you to log in to multiple accounts in the course of using a single website or Mobile Application. In some cases, third-party software providers may have provided us with Personal Information that you shared with them, also to facilitate seamless integration of different software components.

9. Confidentiality

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Personal Information or any other information we collect about you is necessary to (1) comply with a court order or other legal process; (2) protect the rights, property or safety of Switch or another party; (3) enforce our Terms of Agreement, or (4) respond to claims that any posting or other content violates the rights of third-parties.

10. Controlling and Correcting Your Personal Information

Since we use your Personal Information to provide Services to you, your Personal Information must be accurate and up-to-date. If any of your Personal Information changes, please advise us so that we can make any necessary changes (you can either write to us directly or, if you are a registered user of our Software, you can modify some of the Personal Information you have included in your profile).

Upon your written request, we will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may not be possible to remove your account without some residual information being retained by us.

If we hold Personal Information about you and you can establish that it is not accurate, complete, and up-to-date, we will take reasonable steps to correct it.

11. Switch to Your Personal Information

You may ask to Switch to any Personal Information we hold about you. Summary information is available on request. More detailed requests that require archive or other retrieval costs may be subject to our normal professional and disbursement fees.

Your rights to access your Personal Information are not absolute. We may deny Switch when:

  • Denial of Switch is required or authorized by law; Information relates to existing or anticipated legal proceedings against you;
  • When granting you Switch would have an unreasonable impact on other people’s privacy;
  • When to do so would prejudice negotiations with you;
  • To protect our rights and property; or
  • Where the request is frivolous or vexatious.

If we deny your request for Switch or refuse a request to correct your Personal Information, we shall explain why.

12. Security

The security of your Personal Information is important to us. We take reasonable precautions to ensure that your Personal Information is kept safe from loss, unauthorized Switch, modification, or disclosure. Among the steps taken to protect your Personal Information are:

Premises security;

Restricted file Switch to personal information;

Deploying technological safeguards like encryption and security software and firewalls to prevent hacking or unauthorized computer Switch; and

Internal password and security policies.

“Phishing” is a fraudulent practice designed to steal your Personal Information. If you receive an e-mail that looks like it is from Switch asking you for your Personal Information, do not respond. We will never request your password, user name, credit card information, or other Personal Information through e-mail.

A website or other Mobile Application cannot be completely absolutely protected against intentional or malicious intrusion attempts. Further, we do not control the devices or computers or the internet over which you may choose to send Personal Information and cannot, therefore, prevent such interceptions or compromises to your Personal Information while in transit to us. If we learn that your Personal Information has been disclosed in a manner that is not by this Privacy Policy, we will use reasonable efforts to advise you of the disclosure as soon as reasonably possible.

13. Lost or Stolen Information

You must promptly notify us if your Contact Data is lost, stolen, or used without your permission. In such an event, we will remove that Contact Data from your account and update our records accordingly.

14. Integration with Other Software

Our Software contains links to third-party websites and/or is integrated with the software of third-party providers with whom Switch has no affiliation. Except as disclosed in this Privacy Policy, we do not share your personal information with those service providers and we are not responsible for their privacy practices. Some websites and software may be similar to our Software. Please be cautious that you may be using a third party’s software and that this Privacy Policy only covers our Software. Should you decide to visit one of these third-party websites or use their software, we recommend that you read that provider’s privacy policy.

15. Updates and Changes to Privacy Policy

Since we regularly review all of our policies and procedures, we may change our Privacy Policy from time to time. All changes will be posted on our website. In all cases, the use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

16. E-mail

You should be aware that e-mail is not an entirely secure medium. You should be aware of this when using e-mail to send or receive personal or confidential information

17. Limitation of Liability

We make no guarantee as to the security, integrity, or confidentiality of any information transmitted to or from our Software, or stored within our Software.  Beyond our reasonable care to safeguard your information while in transit, Switch does not guarantee the absolute security of electronic communications or transmissions since any transmission made over the internet by anyone individual runs the risk of interception.

You assume the sole risk of transmitting your Personal Information as it relates to the use of our Software, and for any data corruptions, intentional interceptions, intrusions or unauthorized Switch to Personal Information, or of any delays, interruptions to or failures preventing the use of our Software.  In no event shall we be liable for any direct, indirect, special, consequential or monetary damages, including fees and penalties in connection with your use of the Services provided by our Software or connectivity to or from this site to any other site.

If your non-identifiable data is used for research purposes, then the limitation of liability provision set forth above is waived concerning any harms suffered or liabilities incurred as a result of any research activities.

DATA CONSENT

HOW WE PROCESS YOUR DATA

From time to time, you will be asked to provide personal information about yourself (e.g., name and email address etc) to receive or use services on our website. In addition, we automatically collect certain data which we outline below. Some of this information is stored in cookies, you can find out how we use these in our cookies policy.

We process your data in these ways:

  1. For certain legitimate interests:
  2. To improve your experience
  3. To allow you to sign in and stay signed in on our site
  4. To display content suitable to your device
  5. To measure the effectiveness of our website and marketing channels;
  6. To determine the effectiveness of resources e.g., to provide a follow-up email after a user has downloaded a specific resource to understand the business change that may have happened.
  7. To identify and prevent fraud.
  8. To identify and prevent spam; and
  9. If you are one of our partners, to send you email marketing communications.
  10. Based on your consent:
  11. To provide you with a personalized experience i.e., providing content tailored to you.
  12. To send you marketing communications i.e., email marketing and online advertising, for which we will gain separate consent
  13. To measure the effectiveness of our audience profiles on our website and marketing channels
  14. For research purposes and to comply with a legal obligation.

WHAT DATA DO WE COLLECT

The data we collect includes:

  1. Name, email address, postcode, country and telephone number
  2. Organization and job title
  3. IP address
  4. Website actions (i.e., content viewed and downloaded)
  5. Marketing preferences
  6. Audience profiling

Information is specific to an event i.e., dietary needs. The information will only be used for the event.

SHARING YOUR DATA

Subject to applicable data protection law, we may share your data with the following:

  1. Companies who provide services to us
  2. Legal and professional advisors or bodies
  3. Fraud prevention companies
  4. An organization we sell or license the relevant part of the business to retain your legitimate interests.
  5. Any other organization where we have gained your consent or where it is required by law.

Whenever we process data for these purposes, we will ensure that we always keep your Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so, please contact us.

HOW LONG DO WE KEEP YOUR DATA

Website accounts:

We remove accounts that have been inactive for 2 years

Web Mobile Application accounts:

  • Where we can identify when someone last signed in, we remove accounts that have been inactive for 4 years
  • Where we can’t identify when someone last signed in, we will retain the information for the lifetime of the Mobile Application to retain your legitimate interests in using the Mobile Application.

Google Analytics;

User-level and event-level data stored by Google Analytics is automatically deleted from Analytics’ servers after 50 months.

Switch Analytics;

User-level data stored by the Switch analytics tool will be deleted or fully anonymised after 50 months.

Email marketing lists;

You have the option to unsubscribe from one of our email marketing lists, and we will always honour this. We will also periodically clean our lists to ensure they are up-to-date.

YOUR RIGHTS AS A DATA SUBJECT;

At any point, while we have or processing your data, you, the data subject, have the following rights:

  1. Right of Switch – you have the right to request a copy of the information that we hold about you.
  2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  3. Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
  4. Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  5. Right of portability – you have the right to have the data we hold about you transferred to another organization.
  6. Right to object – you have the right to object to certain types of processing such as direct marketing.
  7. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Switch to your personal information

In line with the above rights, you have the right to request a copy of the personal information SWITCH holds about you, to have any inaccuracies corrected, or to request that it be deleted. Please address requests to the person responsible for Data Protection.

Users under 18

If you are under 18, please get your parent/guardian’s permission beforehand whenever you provide personal information to SWITCH. Users without this consent are not allowed to provide us with personal information.

Contact us

If you have any questions about this Privacy Policy or you wish to make a complaint about how your data is being processed by us, or how your complaint has been handled, you have the right to complain directly to the Supervisory Authority and SWITCH’s data protection representative.

The details for the latter are:

SWITCH RECYCLING INNOVATIONS.

29b Adediran Ajao Crescent,

Anthony Village, Lagos State.