Campus Pal Privacy Policy

Effective: January 01, 2021

Posted: January 01, 2021

Thanks for using CampusPal! Here we describe how we collect, use, and handle your personal data when you use our websites, software, and services (“Services”). For more information and details, please see our Frequently Asked Questions page.

Definitions

• Applicable Mobile Application: This Privacy Policy will refer to and be applicable to the “Campus Pal Mobile App."
• Effective Date: "Effective Date" means the date this Privacy Policy comes into force and effect.
• Parties: The parties to this privacy policy are the following data controller: Gender Mobile Initiative ("Data Controller") and you, as the user of this Mobile App. Hereinafter, the parties will individually be referred to as "Party" and collectively as "Parties."
• Data Controller: Data Controller is the publisher, owner, and operator of the Mobile App and is the Party responsible for the collection of information described herein. Data Controller shall be referred to either by Data Controller's name or "Data Controller," as listed above. If Data Controller or Data Controller's property shall be referred to through first-person pronouns, it shall be through the use of the following: us, we, our, ours, etc.
• You: Should you agree to this Privacy Policy and continue your use of the Mobile App, you will be referred to herein as either you, the user, or if any second-person pronouns are required and applicable, such pronouns as 'your", "yours", etc.
• Services: "Services" means any services that we make available on the Mobile App. In this case it in terms of reportage of sexual harassment cases, use of safe spaces and other added features as it pertains to the Institution using the App.
• Personal Data: "Personal DATA" means personal data and information that we obtain from you in connection with your use of the Mobile App that is capable of identifying you in any manner.

General Information

The Campus Pal App is a Mobile Application intended to enable users to report cases of Sexual Harrassment in Institutions of learning. These Reports can be made either in an anonymous or non-anonymous manner depending on the choice of the user.

This privacy policy (hereinafter "Privacy Policy") describes how we collect and use the Personal Data that we receive about you, as well as your rights in relation to that Personal Data, when you use the Campus Pal Mobile App.

This Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Mobile App. The Mobile App may link out to other websites or mobile applications, but this Privacy Policy does not and will not apply to any of those linked websites or applications.

We are committed to the protection of your privacy while you use the Campus Pal Mobile App.

By agreeing to use the Campus Pal Mobile App, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy.

Contact

The Party responsible for the processing of your personal data is as follows: Gender Mobile Initiative. The Data Controller may be contacted as follows:

Gender Mobile Initiative, No.3 Tsukunda House, Central Business District, Federal Capital Territory (FCT) Nigeria

The Data Controller and operator of the Mobile App are one and the same.

Locations

The location where the data processing activities take place is as follows:

Gender Mobile Initiative, No. 3 Tsukunda House, Central Business District, Federal Capital Territory (FCT), Nigeria.

Modifications and Revisions

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner to address evolving privacy matters. If we do so, however, we will notify you and obtain your consent to the change in processing. Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment.

The Personal Data We Receive from You

Depending on how you use the Mobile App, you will be subject to different types of Personal Data collected and different manners of collection:

• Registered users: You, as a user of the Mobile App, will be asked to register in order to use the Mobile App.
  

  During the process of your registration, we will collect some of the following Personal Data from you through your voluntary disclosure:

  • Name
  • Phone number
  • Institution of learning
  • Position in the Institution (such as Student, Academic or non-Academic staff)

  Personal Data may be asked for in relation to:

  • Record keeping and tracking of sexual harassment cases
  • Receiving psychosocial, legal and /or technical support from us (Gender Mobile Initiative)
  • Commenting on our content or other user-generated content on the Mobile App, such as blogs, articles, photographs or videos, or participating in our forums, bulletin boards, chat rooms, safe spaces or other similar features

  By undergoing the registration process, you consent to us collecting your Personal Data, including the Personal Data described in this clause, as well as storing, using or disclosing your Personal Data in accordance with this Privacy Policy.

• Unregistered users: If you are a passive user of the Mobile App and do not register for any service, you may still be subject to certain passive data collection ("Passive Data Collection"). Such Passive Data Collection may include through cookies, as described below, IP address information, location information, and certain browser data, such as history and/or session information.
• All users: The Passive Data Collection that applies to Unregistered users shall also apply to all other users and/or visitors of our Mobile App.
• User Experience: From time to time we may request information from you to assist us in improving our Mobile App, and the Services we sell, such as demographic information or your particular preferences.
• Combined or Aggregated Information: We may combine or aggregate some of your Personal Data in order to better serve you and to better enhance and update our Mobile App for your use.
  
  We may also share such aggregated information without personal data with duty bearers or Civil Society organizations for relevant policies.
• Other Information: In addition to collecting the Personal Data as already described herein, we may also collect the following Personal Data:

  Evidence on cases of Sexual harassment to be reported (be it in written, audio or video format)

The Personal Data We Receive Automatically

Cookies: We may collect information from you through automatic tracking systems (such as information about your browsing preferences) as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using the Campus Pal App, as described above).

For example, we use cookies to make your browsing experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, his or her preferences or the device they are using to access the internet (such as a computer, tablet, or mobile phone). Cookies are mainly used to adapt the operation of the site to your expectations, offering a more personalized browsing experience and memorizing the choices you made previously.

A cookie consists of a reduced set of data transferred to your browser from a web server and it can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.

Cookies do not record or store any Personal Data. If you want, you can prevent the use of cookies, but then you may not be able to use our Mobile App as we intend. To proceed without changing the options related to cookies, simply continue to use our Mobile App.

• Technical cookies: Technical cookies, which can also sometimes be called HTML cookies, are used for navigation and to facilitate your access to and use of the site. They are necessary for the transmission of communications on the network or to supply services requested by you. The use of technical cookies allows the safe and efficient use of the site.
  
  You can manage or request the general deactivation or cancelation of cookies through your browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the site.

  Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit the Mobile App. These are also considered technical cookies when they operate as described.

  Temporary session cookies are deleted automatically at the end of the browsing session - these are mostly used to identify you and ensure that you don't have to log in each time - whereas permanent cookies remain active longer than just one particular session.

• Support in configuring your browser: You can manage cookies through the settings of your browser on your device. However, deleting cookies from your browser may remove the preferences you have set for this Mobile App.

  For further information and support, you can also visit the specific help page of the web browser you are using:

  • Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
  • Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
  • Safari: http://www.apple.com/legal/privacy/
  • Chrome: https://support.google.com/accounts/answer/61416?hl=en
  • Opera: http://www.opera.com/help/tutorials/security/cookies/

• Log Data: Like all websites and mobile applications, this Mobile App also makes use of log files that store automatic information collected during user visits. The different types of log data could be as follows:

  • Internet protocol (IP) address;
  • Type of browser and device parameters used to connect to the Mobile App;
  • Name of the Internet Service Provider (ISP);
  • Date and time of visit;
  • Web page of origin of the user (referral) and exit;
  • Possibly the number of clicks.

The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner in order to verify the correct functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the Data Controller.

For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to the Mobile

App or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of the Mobile App and our users. Such information will be treated according to the legitimate interests of the Data Controller.

Third Parties

We may utilize third-party service providers ("Third-Party Service Providers"), from time to time or all the time, to help us with our Mobile App, and to help serve you.

• We may use Third-Party Service Providers to assist with information storage (such as cloud storage).
• We may provide some of your Personal Data to Third-Party Service Providers in order to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of, and to improve, the Mobile App.
• We may use Third-Party Service Providers to host the Mobile App.
• We may use Third-Party Service Providers to fulfill deliverables in relation to the Mobile app
• We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in this Privacy Policy.
• Your Personal Data will not be sold or otherwise transferred to other third parties without your approval.
• Notwithstanding the other provisions of this Privacy Policy, we may provide your Personal Data to a third party or to third parties in order to protect the rights, property or safety, of us, our customers or third parties, or as otherwise required by law.
• We will not knowingly share your Personal Data with any third parties other than in accordance with this Privacy Policy.
• If your Personal Data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we should not share that information.
• In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.

How Personal Data is Stored

We use secure physical and digital systems to store your Personal Data when appropriate. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction.

Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.

Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for cancelation of your account or other general request for the deletion of data.

In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but in no event later than two weeks, and we will follow all applicable laws in Nigeria regarding such breach.

Purposes of Processing Personal Data

We primarily use your Personal Data to help us provide a better experience for you on the Mobile App and to enable you to safely report cases of Sexual Harassment on the Campus Pal Mobile App.

Information that does not identify you personally, but that may assist in providing us an overview of our users . Such information may include, but is not limited to, interests based on your cookies.

Personal Data that may be considering identifying may be used for the following:

1. Ascertaining the extent to which sexual harassment cases are reported and addressed
2. Improving your personal user experience
3. Communicating with you about your user account with us
4. Advising you about updates to the Mobile App or related Items

Disclosure of Personal Data

Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:

1. To satisfy any local, state, or Federal laws or regulations
2. To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legally constituted bodies such as the Independent Sexual harassment Prohibition Committee
3. To bring legal action against a user who has violated the law or violated the terms of use of the Mobile App
4. As may be necessary for the operation of the Mobile App
5. To generally cooperate with any lawful investigation about our users
6. If we suspect any fraudulent activity on the Mobile App or if we have noticed any activity which may violate our terms or other applicable rules

Private and Public Information

We may allow users to post their own content or information privately on our Mobile App except stated otherwise. Such content or information may include, but is not limited to, photographs, status updates, blogs, articles, or other personal snippets. These can be placed in the section where cases are reported or in the safe space segment, the access learning Centre or the campus news segment. Any section of the Application which is considered public would be out rightly indicated in the Application.

Opting out of Transmittals from Us

From time to time, we may send you informational or marketing communications related to the Mobile App such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email: info@gendermobile.org

You may also click the opt-out link which will be provided at the bottom of any and all such communications.

Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of the Mobile App or about your account with us.

Modifying, Deleting, and Accessing your Information

If you wish to modify or delete any information we may have about you, or you wish to simply access any information we have about you, you may do so from your account settings page.

Acceptance of Risk

By continuing to the Mobile App in any manner, you manifest your continuing access to this Privacy Policy. While we agree to keeping your data and information secure, please note that any transmission of information or data outside the Mobile App will be at your own risk.

Your Rights

You have many rights in relation to your Personal Data. Specifically, your rights are as follows:

• the right to be informed about the processing of your Personal Data
• the right to have access to your Personal Data
• the right to update and/or correct your Personal Data
• the right to portability of your Personal Data
• the right to oppose or limit the processing of your Personal Data
• the right to request that we stop processing and delete your Personal Data
• the right to block any Personal Data processing in violation of any applicable law
• the right to launch a complaint with the National Communications Commission (NCC) and legal bodies in Nigeria

Such rights can all be exercised by contacting us at the relevant contact information listed in this Privacy Policy.

Contact Information

If you have any questions about this Privacy Policy or the way we collect information from you, or if you would like to launch a complaint about anything related to this Privacy Policy, you may contact us at the following email address: info@gendermobile.org.