One Number

1. Introduction

CedarView Communications Limited respects your privacy and is committed to protecting your data.

This Data Privacy and Protection Policy describes your privacy rights regarding CedarView Communications Limited policies and procedures on the collection, use storage, sharing and protection of your personal identifiers, electronic network activity information, professional information, location information, and other types of information.

This Data Privacy and Protection Policy applies to all forms of systems, operations, and processes within our environment that involve the collection, storage, use, transmission, and disposal of Personal Information (described below).

It applies to collection and disclosure of your information when you use the Service, how the information collected is used, how we protect it, and tells you about your privacy rights and how the law protects you.

This Data Privacy and Protection Policy is strictly restricted to only our Service and therefore does not apply to services that are not owned or controlled by us, including third-party platforms/websites.

2. Consent

We use your personal data to provide and improve the Service. By accessing or using the Service in any manner, you indicate to us that you have read and accepted this Data Privacy and Protection Policy and consent to the data practices described in this Data Privacy and Protection Policy.

You agree that upon granting us your consent, you have the legal capacity to give consent and you are aware of your privacy rights and your option to withdraw your consent at any given time.

You agree to the collection and use of information in accordance with this Data Privacy and Protection Policy.

If you do not accept this Data Privacy and Protection Policy and do not meet or comply with the provisions set forth herein, then you may not use our Service.

3. Interpretation and Definitions

3.1 Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

3.2 Definitions

For the purposes of this Data Privacy and Protection Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to One Number, the software program provided by the Company.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to CedarView Communications Limited, Plot 724a, Babatunde Atere, Omole Phase 2, Olowora, Lagos State, Nigeria.

• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

• Personal Data is any information that relates to an identified or identifiable individual.

• Service refers to the Application.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the service infrastructure itself (for example, the duration of a page visit).

• You means the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service, as applicable.

4. Collecting and Using Your Personal Data

Types of Data Collected:

Personal Data

While using our service, we may ask you to provide us with certain personally identifiable information of individuals that makes them easily identifiable. Or can be used to contact you. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your device's internet protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device You use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

5. Information Collected while Using the Application

While using our application, in order to provide features of our application, we may collect, with your prior permission:

Information regarding your location

We use this information to provide features of our service and to improve and customize our Service. The information may be uploaded to the company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through your device settings.

5.1 Purpose Limitation

We collect Personal Data only for identified purposes and for which consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose.

5.2 Data Minimization

We limit Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Data is necessary and where the purpose allows, anonymized data will be used.

6. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including monitoring the usage of our Service.

• To Manage Your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.

• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Service.

• To Contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, marketing content, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about, however, we will provide you with an option to unsubscribe if you do not want to receive such information from the Company.

• To manage Your requests: To attend and manage your requests to us.

• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our service users is among the assets transferred.

• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our service, products, services, marketing, and your experience.

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to contact you.

• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Data Privacy and Protection Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

In providing you with our Service, we may rely on third-parties located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable data on computers or servers in foreign jurisdictions. In situations where this may occur, we will endeavor to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and that your personally identifiable data is treated in a safe and secure manner.

7. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal and statutory obligations.

We are statutorily obligated to retain Your Personal Data provided to us with in order to process transactions, ensure settlements, make refunds, and identify fraud in compliance with laws and regulatory guidelines applicable to us and our partners. Therefore, even after discontinuance of our Service, we will retain certain Personal Data and Usage Data to comply with these obligations. All Personal Data shall be destroyed by us where possible. For all Personal Data and records obtained, used and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

The length of storage of your Personal Data shall, amongst other things, be determined by:

• the contract terms agreed between us and the Data Subject or as long as it is needed for the purpose for which it was obtained; or

• whether the relationship has statutory implication or a required retention period; or

• whether there is an express request for deletion of the Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require us to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or

• whether we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

8. Data Subject Rights

Once your Personal Data is held by us, you are entitled to reach out to us to exercise the following rights:

• Request access to your personal data (commonly known as a “data subject access request”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may notify you of our refusal to comply with your request in these circumstances. Where we have reasonable doubts concerning the identity of the natural person making the request for information, we may request the provision of additional information necessary to confirm the identity of the Data Subject. Where data is held electronically in a structured form, such as in a Database, as the Data Subject, you have a right to receive that data in a common electronic format.

• Right to request correction of the Personal Data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Right to request erasure of your Personal Data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with Nigerian law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Right to object to the processing of your personal data: Where we are relying on a legitimate interest (or those of a third party) there maybe something about your particular situation which could justify an objection to processing on this ground as you may feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data 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.

• Right to request restriction of processing of your Personal Data: This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

  • If you want us to establish the data’s accuracy;

  • Where our use of the data is unlawful but you do not want us to erase it;

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Data to you or to a third party: We will provide to you, or a third party you have chosen, your personal data 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.

• Withdraw consent at any time where we are relying on consent to process your Personal Data: 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.

Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations. You may decline to provide your Personal Data when it is requested by us. You may review and update your Personal Data directly or by contacting us [email protected]

9. Transfer of Your Personal Data

Third Party Processor within Nigeria and Foreign County

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

The processing by such third parties shall be governed by a written contract with us to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with the terms of this Privacy Policy.

We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

• comply with a legal obligation, process or request (including tax and related reporting requirements);

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

• detect, prevent or otherwise address security, fraud or technical issues; or

• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other

Please see the list of third-party processors we share your personal data with on our website.

Where Personal Data is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Data. In particular, we 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 Data out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation ("NDPR"). We will therefore only transfer Personal Data 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 us 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 us 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.

We will take all necessary steps to ensure that your Personal Data is transmitted in a safe and secure manner. Details of the protection given when your Personal Data is transferred outside Nigeria shall be provided to you upon request.

10. Our Lawful Basis for Processing Personal Data

We will only use and process your Personal Data as permitted by the Nigerian Data Protection Regulation 2019 (Nigerian Data Protection Regulation). We have set out below a description of all the legal bases we may rely on to process your personal data:

• where you have given us consent to the processing of your personal data for one or more specific purposes;

• where processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

• where processing is necessary for compliance with a legal obligation to which we are subject;

• where processing is necessary in order to protect your vital interests or the vital interests of another natural person, and

• where processing is necessary for the performance of a task carried out in the public interest or in exercise of an official public mandate vested in us.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data. Please contact us by sending an email to: …[NAME OF DPO; [EMAIL OF DPO], if you need details about the specific legal ground we are relying on to process your personal data where more than one ground may have been used to process your personal data.

For the purpose of this Data Privacy and Protection Policy, consent means any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.

11. Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Age Restriction. Our Service are not directed to persons under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18.

If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please notify Us at [email protected]. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

12. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

13. Updates, Modifications and Amendments

We may update Our Data Privacy and Protection Policy from time to time. We advise that you check this page often, referring to the date of the last modification on the page. We will also try to notify You of any changes by posting the new Privacy Policy on this page. The changes will not be retroactive.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

Changes to this Data Privacy and Protection Policy are effective when they are posted on this page. By continuing to use our Services after the changes become effective, you agree to be bound by the revised Data Privacy and Protection Policy

14. Dispute Resolution

Any dispute arising out of or in connection with the use of this App, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by the Lagos Court of Arbitration (International Centre for Arbitration and ADR).

The number of arbitrators shall be one. The seat, or legal place, of arbitration shall be Lagos State, Nigeria.

The language to be used in the arbitration shall be English. The decision of the arbitrator shall be final and binding and shall not be appealable to any court in any jurisdiction. However, any Party may enter such decision in any court having competent jurisdiction.

15. Dispute Resolution

You may file a complaint in accordance with this Data Privacy and Protection Policy if you believe that any provision of this Data Privacy and Protection Policy or your privacy rights have been violated in respect of your personal information or if your access to our Service have been compromised, to enable us to take the necessary steps towards ensuring the security of your Personal Data. All complaints must be addressed to the Company by sending an email to our Data Protection Officer using the following contact details: [email protected]

Please note that, the complaint and resolution procedure is not prejudicial to your right to complain to the data protection authorities (in this case, the National Information Technology Development Agency (NITDA)) using the following contact details:

We will notify you of any breach and also notify National Information Technology Development Agency (NITDA) within 72 hours of becoming aware of such a breach.

You may also seek redress in a court of competent jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authorities. Kindly contact us in the first instance by sending an email to:[email protected]

16. Questions and Inquiries

You may contact us if you have any questions relating to this Data Privacy and Protection Policy or would like to find out more about exercising your data protection rights. All questions, comments, and requests regarding this Policy should be addressed to [email protected]

• By email: [email protected]

• By phone number: +2348034722472