PRIVACY POLICY

  1. Introduction
  2. Information we collect
  3. Use of Information by Simbi
  4. Communication of Information with third parties
  5. Consent
  6. How long do we keep the Information
  7. International Data Transfers
  8. User rights
  9. Additional Rights for California Residents
  10. Information Security and Protection
  11. Links to third party sites
  12. cookies
  13. Third Party Advertising and Analytics – Interest-Based Advertising Disclosure
  14. Privacy for minors
  15. Applicable law and jurisdiction
  16. Changes to Privacy Policies

 

  1. Introduction

This Privacy Policy explains how Simbi collects, uses, stores, shares and, in general, processes your Personal Information and/or other information from or about users (collectively “Information”). Personal Information (Personal Data) means information that can be used to identify the user. For Nigeria residents the definition of Personal Information is set forth in Section 65 Nigeria Data Protection Act, 2023.

By accessing and/or using the games, applications, purchases from the Simbi apps or website (the “Services”), the user authorizes the collection, transfer, manipulation, storage and disclosure of their information and other uses. , as described in this Privacy Policy.

If the user has any questions about this Privacy Policy or about how Simbi uses their Personal Information, cookies or similar technologies, they can contact Simbi at help@simbi.ng , or failing that, stop using the Services Users who If you are in Europe, you can contact our Data Protection Officer at dpo_gdpr@simbi.ng

As set forth in the Terms and Conditions with respect to the Services (“ Terms of Service ”), the user must be of legal age in accordance with the laws of his or her state or country of residence, or have the consent of his or her parents. parents or legal guardian, and that your parents or legal guardian agree to these Privacy Policies. For users located in the European Union, the user must be at least 16 years old to access and/or use the Services. If the user is under 16 years of age, they must have the consent of their legal guardian and only to the extent that the legal guardian agrees with this Privacy Policy to access and/or use the Services. If the user’s applicable national legislation allows it, the user under 16 years of age can access the service, provided that he or she is not less than 13 years of age.

  1. Information we collect

Simbi, in order to provide its Services, receives and processes User Information, such as:

2.1 Information that the user provides us: when the user completes the forms at the time of accessing or using the Services, or creates an account with us, we collect the Personal Information that you provide us, which may include your email, name, name of user and telephone number, photograph, and other personal information that the user decides to provide us or include in your account.

2.2 Information we obtain automatically : We also collect information about you and your use of the Services, your interactions with us and our advertising, as well as information related to the electronic device used to access or use the Services (for example, telephone mobile or tablets). This information includes:

  • When you register with us using your Google account, we collect your name, email and profile picture. This information is collected by Google, which provides it to us in accordance with the terms of Google’s privacy policy. You can control the information we receive from Google through the privacy settings in your Google account.
  • Some of our Services allow users to create questions and answers to be used in our games. When the user submits questions and answers, we collect that information.
  • When the user requests assistance from the Simbi customer support team, the contact information they provide will be collected, as well as information about their use of the app or their activity on the Service, their user identification number and the correspondence and any type of information contained therein.
  • Log Data and Game Usage Information: The Services automatically log information created through your use of the Services. This data may include information such as your IP address, browser type, operating system, referring website, pages visited, location, mobile carrier, device and application ID, search terms, and cookie information. Log data is received when the user interacts with the Services. This data is used to provide the Services and to evaluate, personalize and improve them. Simbi also collects and stores the user’s app usage history, including, for some games, their question and answer history..
  • Simbi may keep track of how you interact with links found throughout the Services, including your preferences for email notifications, and interaction with third-party services and customer applications, to through click redirection or other means.

2.3 Information from other sources: We also collect Information about the user and about the use of the Services from other sources such as:

  • Third Party Service Providers: Simbi uses a variety of third party services to assist in the provision of the Services, such as hosting services, among others. These third-party service providers may collect information sent from your browser as part of a web page request, such as cookies or your IP address, location, and unique device identifiers.

2.4 We collect information that you provide to us through questionnaires, surveys, feedback submissions, and your interactions with our Services, including account creation. This data may include preferences, usage patterns, and non-identifying information. Our primary goals in collecting this data are to improve our Services, tailor your experience, and, in accordance with our terms of service, share that information for advertising purposes.

  1. Use of Information by Simbi

You agree that Simbi, its Service Providers and/or its Advertising Partners, on behalf of Simbi, may use the information and categories of information (as set forth in the NDPA 2023) that they collect to the following purposes:

  • provide, personalize and improve the Services and advertising (including third-party products and services) available through or outside the Service;
  • show you advertising from our partners and others that may be of interest to you;
  • contact you as part of user support; to send you updates or information about the Services;
  • manage your account and your relationship with the Services and improve your experience when using them;
  • improve the Services, conduct research, conduct surveys and engage with you, for example by sending you communications for these purposes;
  • marketing and promotion of the Services and products, direct and third party commercial purposes;
  • personalize and optimize the Services, promotional content and/or advertising;
  • create reports, analyzes or similar services for research or business intelligence purposes;

The user may use their account settings to unsubscribe from some notifications from Simbi. You may also be able to unsubscribe from some messages using the instructions contained in the notification.

  1. Communication of Information with third parties

Simbi may share the user’s Personal Information with:

  • Service providers. We may establish business relationships with other companies that we believe to be trustworthy after we have confirmed that their privacy practices are consistent with ours. For example, we may contract with Service Providers to provide us with certain services such as hosting and maintenance, data storage and management, marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security practices and procedures, appropriate to the nature of the information involved, in order to protect the user’s Personal Information from unauthorized access, use or disclosure. Service Providers are not permitted to use your Personal Information in ways other than those indicated by us.
  • Third parties and the general public. When using the Website or Services, you may provide certain Personal Information to others. For example, when you create a profile, any other user will be able to see your username or pseudonym, as well as other profile information that the user has chosen to make public (such as your name or username, photograph and other information you choose to provide to others). In turn, when you submit content to us (including questions and answers), you give us permission to use that content for any purpose, including publishing and distributing that content on or off our Services, through third parties. When you participate in competitions, we may post, share or disclose your Personal Information and other information about you in connection with the competition.
  • Social Networks Like most services, if you register for our Services through a third party such as Google, your account with us will automatically be connected to your account and your Google username and profile photo will be to be part of your Simbi user profile.
    These platforms, or any other similar third-party application or website, belong to third parties and not to Simbi. The user must ensure that they read their terms of service and privacy policies.
  • Marketing partners who assist us with promotional efforts and advertisers who make it possible for us to offer the Services free of charge. As described in Section 13 regarding “ Third Party Advertising and Analytics – Interest-Based Advertising Disclosure ,” our advertising partners may collect advertising identifiers and other Personal Information for the purpose of providing you with Interest-based advertising.
  • In compliance with current legislation and with public organizations, and protection of our Site, Services and others.Simbi may disclose the user’s Personal Information to the extent reasonably necessary to comply with a law, regulation or legal request by competent bodies. We may access, read, preserve and disclose your Personal Information, your non-personal information, your user content, logs of chats or other communications, any content you post or upload, and any other information about you to government officials. and law enforcement or private agencies, if in our sole discretion, we deem necessary or appropriate in order to (i) comply with any applicable law (including court orders and subpoenas), (ii) investigate potential violations of, or enforce our “ Terms of Service ”, (iii) detect, prevent, or otherwise address fraud, security, or technical issues, (iv) respond to user support requests, (v) protect the security, property, or rights of our company, our users, or any third party, or (vi) prevent or stop any illegal, unethical or legally punishable activity.
  • Anonymous or aggregated information.Simbi may use and share aggregated and/or anonymous information about users with third parties. The user cannot be personally identified through this information.
  • Other communications.We may share Information (including Personal Information and other information and data about users) with companies that control, are controlled by, or are under the same control as our Company. If our Company is merged, acquired, sold, or if some or all of our assets are transferred, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if it, in our discretion, results in your Personal Information being handled in a manner that materially differs from these Privacy Policies.

The user acknowledges that he has no expectation of privacy with respect to the information mentioned above, the content he sends us (including questions and answers), and the content that you provide in connection with competitions, your profile information that you choose to make public, or your use of these features of the Site or Services.

If you are a Nigeria resident, you should refer to Section 25 Nigeria Data Protection Act for more information.

  1. Consent

The legal basis for the processing of personal data described in this Privacy Policy will depend on the personal data involved and the specific context in which we collect and use it. We may process Information on the basis of:

  • The need for processing for the execution of the contract signed with the user (to provide our Services).
  • Our legitimate interest, without conflicting with the user’s own data protection interests, rights or fundamental freedoms (creating statistics and helping us better understand our needs and improve the Services).
  • In some cases, legal obligation to collect your personal data.

In any case, by accessing and/or using the Simbi Services, the user gives their consent to:

  • Collect, store, use, sell, share and otherwise process your Personal Information, including for advertising purposes, in accordance with this Privacy Policy.
  • Transmit your Personal Information outside your country of residence.
  • Use cookies and other similar technologies.

  1. How long we keep the Information

Simbi may retain Information (including Personal Information) for as long as necessary to fulfill the purposes for which it was collected, or even after the user has discontinued or deleted any account or after the provision ends of the Services, if the retention of such Information is necessary to comply with legal obligations, comply with regulatory requirements, resolve disputes between users, prevent fraud, backup, archive, and/or audit, protect the rights or property of Simbi, or any other use.

How long we retain information for users located in Europe

To determine the retention period of the Information, we follow the following criteria:

  • Information obtained to provide the Services, send you updates or information about the Services and manage your account: as long as you do not ask us to close your account;
  • Information obtained when you consent to the sending of commercial communications and advertising: until you unsubscribe or request that we delete it.
  • We may retain some Information to comply with our legal obligations, to administer our rights (for example, to assert our claims in court) or for statistical or historical purposes.
  • When we no longer need to use your personal data, it will be deleted from our systems and records or anonymized so that we can no longer identify it.

  1. International Data Transfers

Your Personal Information may be transferred to, and stored on servers located outside of your country of residence, to third countries outside the European Economic Area (or EEA), including countries where privacy laws are not as protective as those of their jurisdiction.

These third countries may include Argentina and Uruguay, with respect to which the European Commission has declared them as countries with an adequate level of protection through Commission Decision 2003/490/EC of June 30, 2003 (Argentina) and Decision 2012/484/EU of the Commission, of August 21, 2012 (Uruguay).

Personal data may also be transferred to the United States or another country and processed there. Whenever we transfer User Information outside the jurisdiction in which it is located, we make sure to ensure that the international data transfer is carried out in accordance with applicable regulations.

Regardless of the country in which you reside or provide information, the user authorizes Simbi to store and/or use the Information in accordance with this Privacy Policy in any country where Simbi may operate.

  1. User rights

8.1 User rights

You may review, correct, update or change your Personal Information by changing the relevant settings in your account.

The user may choose not to receive certain commercial communications electronically through the “unsubscribe” option contained within said emails. However, you cannot opt ​​out of receiving all communications from Simbi, such as emails about your account status.

Additionally, you can delete your profile information. However, the information that the user has shared through the Services on any social network or third-party platform cannot be modified or deleted when it is under the control of a third-party network and/or platform.

This Privacy Policy is not intended to limit any legal defences or objections that you may have against a third party, including a request by a government to disclose your information.

For questions or concerns regarding this Privacy Policy, please email us at help@simbi.ng.

8.2 Rights of users located in Europe As the owner of the Personal Information that we collect and process, the user has the following rights:

  • Right to Information: you have the right to obtain clear, transparent and easy-to-understand information about how we use your personal data and about your rights; information that we provide to the user through this Privacy Policy.
  • Right of access: you have the right to access and obtain a copy of the information we process about you, within certain legal limits.
  • Right to rectification: right to have your data rectified when it is inaccurate or incomplete.
  • Right to deletion or right to be forgotten: right to have your personal data deleted or deleted when, among other reasons, your data is no longer necessary for the purposes for which it was collected. However, Simbi may have legal or legitimate reasons to retain them.
  • Right to object to the processing of your data in certain circumstances, for example, direct marketing, including profiling.
  • Right to withdraw the consent given at any time when the treatment is based on consent.
  • Right to limit processing: you have the right to request the limitation of the processing of your data in the legally established cases. Likewise, the person responsible for the treatment may limit the processing when the user disputes the accuracy of the personal data, during the period that allows the person responsible to verify the accuracy of the same; or when the user objects to the treatment, while it is verified whether it is appropriate.
  • Right to data portability: you have the right to move, copy or transfer the data that you have provided to us in a structured, commonly used and machine-readable format, from our database to a different one. It is only possible to exercise this right with respect to the data you have provided, when the processing is based on the execution of a contract or on your consent and the processing is carried out by automated means.
  • Right to file a claim with the competent Control Authority if you consider that the treatment does not comply with current regulations.

8.3 Exercise of rights for European residents

To exercise any of the rights granted to the European resident user, you may submit a written request specifying the following information: name and surname, address for notification purposes, copy of the National Identity Document or Passport, and request in which specify the request. In the case of representation, it must be proven by a reliable document.

This request must be sent to the Simbi Data Protection department at one of the following addresses.

8.4 Right of deletion or ‘right to be forgotten’ of the user:

All users who are not covered by sections 8.2 and 8.3 will have the right to have their personal data deleted when, among other reasons, the data is no longer necessary for the purposes for which it was collected. However, Simbi could have legal or legitimate reasons to keep them. Email address for these purposes: help@simbi.ng

2.1 There is some Personal Information that will be public information within our Services, such as any information you share publicly or data about your public profile, content, followers and who you follow on our Services. This public information is available to anyone within our Services.

Email address for these purposes: dpo_gdpr@simbi.ng

 

9. Additional Rights for Nigeria Residents

The Nigeria Data Protection Act (“NDPA”) grants specific rights over your Personal Information to Nigerians. NDPA establishes the following definition of Personal Information: “information relating to an individual, who can be identified or is identifiable, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, psychological, cultural, social, or economic identity of that individual.” “Personal Information” does not include: (i) public information from government records; (ii) anonymous or aggregated consumer information; (iii) information excluded from the scope of NDPA.

This section describes specific additional rights regarding Personal Information of Nigeria residents and sets forth how to exercise those rights.

9.1 Personal Information collected by Simbi

In particular, Simbi has collected the following categories of personal information from its users in the last twelve (12) months: (i) identifiers (such as name, email address, phone numbers and device ids).

For more details about the personal information that Simbi has collected in the last 12 months see section 2 “Information we collect”.

We expressly declare that we will not collect additional categories of information (mentioned in this section and in the information detailed in section 2 “Information we collect”) or use the collected information for purposes materially different from, unrelated to or incompatible with those mentioned in section 3 “Use of Information by Simbi” without providing prior notice.

9.2 Additional rights and options

NDPA grants specific rights over your Personal Information to Nigeria residents. This section describes these rights and sets out how to exercise them.

(i) Access to specific information

You have the right to request that Simbi disclose to you certain information about your Personal Information collected and used in the last twelve (12) months. Once your request is received and confirmed (see section 9.3 i) “Exercise of data access and deletion rights”), we will inform you: (i) the categories of your personal information that we have collected; (ii) the categories of sources from which we have collected your Personal Information; (iii) the commercial or business purpose for collecting or selling such personal information; (iv) the categories of third parties with whom we share your personal information; (v) your specific Personal Information collected; and (vi) if we have sold or disclosed your Personal Information for a commercial purpose, two separate lists detailing: (a) sales, identifying the categories of Personal Information that each category of third parties have purchased; and (b) disclosures, identifying the categories of Personal Information that each category of third parties have received.

(ii) Rights to data deletion

You have the right to request that Simbi delete any Personal Information that we have collected and retained, except for certain exceptions mentioned in the NDPA. Once your request is received and confirmed (see section 9.3 i) “Exercise of rights of access and deletion of data”), we will proceed to delete your Personal Information unless an exception is applicable.

 

9.3 Exercise of rights of Nigeria residents

  1. i) Exercise of data access and deletion rights

To exercise your rights of access and deletion of data, you can submit a request through:

  • By filling out the form that is displayed when you click on “Submit a request” in the Help or Support section of our applications,
  • By clicking the ‘‘Delete Account’’ button under the profile page on the app
  • Sending an email to help@simbi.ng

Only you may submit a request about your Personal Information (“Verifiable Request”). A request will be considered a Verifiable Request when Simbi has been able to verify the identity of the requester.

You may only request a Verifiable Data Access Request twice in a 12-month period. The request must:

  • Provide sufficient information that allows us to reasonably verify that you are the person from whom we have collected Personal Information or your legal representative. Simbi may request the necessary information to verify your identity in accordance with current laws.
  • Describe your request with sufficient detail to allow us to correctly understand, evaluate and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to request such information, and confirm that the Personal Information is yours.

You do not need to create an account with us in order to submit a Verifiable Request. In turn, we will only use your Personal Information submitted in a Verifiable Request to evaluate and fulfill that request.

There are other ways in which you can control the personal information we collect. For example, you can disconnect your Google account from our apps, or delete our applications from your device. Also, you can reset your advertising identifier or you can opt out of receiving personalized ads/interest-based advertising from Simbi or its advertising partners through your device (see section 13.3). You can also limit or eliminate the use of cookies in your internet browser.

  1. ii) Response time and application form, for Nigeria residents

Simbi uses its best efforts to respond to a Verifiable Request within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and the extension period.

Any disclosure we provide only covers the 12-month period preceding the Verifiable Request. In the event that we are unable to comply with a request, our response will explain the reasons for not doing so.

We will not charge a fee or price to process or respond to your Verifiable Request, unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

9.4 Non-Discrimination

We will not discriminate against you for exercising any of your NDPA rights. Unless permitted by policy, we will not: (i) deny you services; (ii) we will charge different prices or rates for services, including by granting discounts or other benefits, or imposing penalties; (iii) we will provide a different level or quality of services; (iv) we will suggest different prices or rates for the services or a different level or quality of services.

Notwithstanding the foregoing, Simbi may charge a user a different price or rate, or provide a different level or quality of goods or services, or offer rewards and incentives, if that difference is reasonably related to the value provided to the user by the value of the user data.

 

  1. Security and protection of Information

Simbi maintains appropriate technical and organizational measures to protect the Information against any alteration, loss, destruction, unauthorized treatment or access, as well as any other illegal form of processing of Personal Information.

However, the storage or transmission of data over the Internet or other network cannot be guaranteed to be 100% secure. Consequently, Simbi does not guarantee that the information will not be accessed, disclosed, altered or destroyed due to failure to comply with any of the aforementioned security measures.

  1. Links to third party sites

In the Services the user may find links to third party websites. The user understands that by clicking on these links, any data subsequently provided will be governed by the privacy policy of said third party and not that of Simbi. Accordingly, Simbi assumes no responsibility for the content, protection or security of any third party websites and we recommend that you check these policies before submitting personal data to third party websites.

In particular, we may offer the user the opportunity to register for our Services using social media login. If you do so, the user understands that they share their social profile information with SIMBI and that the personal data shared depends on the settings of their social media platform. Please consult the privacy policy of the social networks in question to learn how your Personal Information is treated.

  1. Cookies

By accepting this Privacy Policy, by accessing and/or using the Services, the user accepts the use of cookies and other similar technologies by Simbi, as well as third parties such as Google or one of our advertising partners. These third parties may place and read cookies and other similar technologies, such as device identifiers, web beacons, and tracking pixels, which collect anonymous information when you use the Services.

These technologies are used to provide the Services to the user, offer advertising that is of interest to them, as well as improve the Services, also facilitating the use of our applications and web platform.

What are cookies?

Cookies and these other technologies are small files or devices that are downloaded to the computer or other equipment, such as a mobile device, that the user uses when accessing and/or using certain web pages or certain online services. Cookies are used to store and retrieve data about the user’s browsing habits, their equipment, connection time, analyze the operation of the page, etc. and, with this, be able to provide certain services, offer advertising or be able to implement improvements or new services.

What cookies do we use?

Simbi and third parties use the following cookies:

  • Technical cookies: These are those that allow the User to navigate through a web page, platform or application and use the different options or services that exist there, such as, for example, controlling traffic and data communication, identifying the session, access restricted access parts, use security elements while browsing, store content for broadcasting videos or sound or share content through social networks.
  • Simbi may use this type of cookie to recognize the user’s device, for example, by identifying its device id, and to collect data such as the model of your device, operating system and screen size, other installed applications. on your device, date and time, the subject of the advertisements you have clicked on or scrolled through, and other information about how you use the Services.
  • Personalization cookies: These are those that allow the user to access the service with some general characteristics predefined based on a series of criteria on the user’s terminal, such as the language, the type of browser through which the user accesses the service. , the locale from where you access the service, etc.
    Simbi can use this type of cookies to store access information and thus prevent the user from having to register again and again; to allow the Services to interact with social networks or third-party platforms where the user has chosen to allow such interaction; to allow payments to be processed when the user submits payment instructions; to allow Simbi and third parties to provide you with more personalized services; and to collect other information about your use of our Services.
  • Analysis cookies: These are those that allow the person responsible for them to monitor and analyse the behaviour of the users of the websites and/or services to which they are linked. The information collected through this type of cookies is used to measure the activity of the websites, applications or platforms and to prepare navigation profiles of the users of said sites, applications and platforms, in order to introduce improvements in based on the analysis of usage data made by users of the service.
  • Advertising cookies: These are those that allow the management of advertising spaces that third parties, such as Google and our advertising partners, have included in our web platform and applications from which the requested service is provided, being used to limit the frequency and organize advertising that is received.
  • Behavioural advertising cookies: These are those that allow the management of advertising spaces that, where appropriate, have been included in a web page, application or platform from which the requested service is provided. These cookies store information on user behaviour obtained through continuous observation of their browsing habits, which allows the development of a specific profile to display advertising that may be important or interesting to you.

Third parties, such as Google and our advertising partners, may use cookies on and off the Services for the purposes above, including collecting information about your online activity over time and across websites. , and using that information to provide advertisements on our Services or on other websites about products and services likely to be of interest to you.

In particular, Simbi uses the following third-party cookies that collect information for statistical purposes, use of the web platform by the User and to include advertising in our Services:

  • Google Analytics by Google, Inc., a company whose headquarters are located at 1600 Amphitheater Parkway, Mountain View, CA 94043, United States, which is used to carry out our statistics and analysis on the number of visits, duration, partner data user demographics (language, location, Internet provider…), etc.

The user may allow, block or deactivate the cookies installed on their computer by configuring the web browser on their computer or mobile device. Internet browsers are usually set by default to accept Cookies, but they can be easily disabled by changing the browser settings.

Many cookies are used to improve the usability or functionality of websites/applications, therefore, if the user decides to disable cookies, some functionalities of the Services may not function properly or their quality may be affected. Alternatively, if you do not wish to have data collected as described in this clause, you must stop using the Services.

Below, the user is offered some links with instructions to follow to delete, enable and manage cookies, depending on the browser used:

 

  1. Third Party Advertising and Analytics – Interest-Based Advertising Disclosure – Nigeria Residents’ Right to Opt Out

13.1 Advertising Partners and Interest-Based Advertising Disclosure:

We allow advertising on our free Services so that we can continue to offer these Services for free. Our advertising partners may collect advertising identifiers (such as the Apple Identifier for Advertising (IDFA) or the Google Advertising ID (AAID)) to enable and optimize the advertising they serve, to provide personalized advertisements related to the user’s interests (“ Interest Based Advertising ” or “ IBA ”) and to improve and evaluate the effectiveness of advertising campaigns. These identifiers are non-permanent, non-personal device identifiers. As explained in Section 12 above regarding the use of “Cookies” , advertisers and third parties may also place and collect cookies and other anonymous identifiers. Third parties such as Facebook and our advertising partners may collect information about your online activity user over time and across different websites, and may use such information to offer advertisements on other websites about goods and services that may be of interest to you.

Our Systems do not recognize “Do Not Track” signals, but many of the third-party companies described above allow the user to opt out of personalized advertising practices, or alternatively, the user may opt out of collecting certain Personal Information in accordance with the provisions of clause 13.2

13.2 Simbi complies with the Digital Advertising Alliance’s Set of Self-Regulatory Principles (DAA Principles). The user may opt out of receiving personalized ads/interest-based advertising by Simbi or provided on its behalf:

To learn more about these advertising practices or to opt out of receiving this type of advertising you can visit NAI: Network Advertising Initiative or WebChoices or Your Online Choices . Likewise, for Android operating systems, the user can choose to exclude interest-based advertising. To do this, open “Google Settings” from the applications tab, click on “Ads” and select “Disable Ads Personalization” ( https://developer.android.com/google/play-services/id.html ) . Please note that this will prevent your phone from allowing you to receive personalized advertising recommendations. On iOS operating systems, the user may choose to opt out of interest-based advertising by clicking “Settings,” then “Privacy,” “Advertising,” and enabling the Limit Tracking option ( https://support.apple.com/en- us/HT202074 ). Please note that this will prevent your phone from allowing you to receive personalized advertising recommendations.

The following is part of the list of our Advertising Partners and their Privacy Policies:

The user can obtain a complete and updated list of our Advertising Partners by contacting help@simbi.ng  .

13.3 Right to Opt Out for Nigeria Residents

If you are a Nigeria resident please follow the steps below to complete the process:

For Android operating systems, the user can choose to opt out of interest-based advertising. To do this, open “Google Settings” from the applications tab, click on “Ads” and select “Disable Ads Personalization” (://developer.android.com/google/play-services/id.html)

On iOS operating systems, the user may choose to opt out of interest-based advertising by clicking “Settings,” then “Privacy,” “Advertising,” and enabling the Limit Tracking option (https://support.apple.com/en- us/HT202074).

Please note that after exercising the Right to Opt-Out, you will prevent your phone from receiving personalized advertising recommendations on your device.

13.4 Advertising Partners may collect exact and approximate location information: At the time you activated your game or Services, you authorized our advertising partners to collect exact or approximate location information from your mobile device and use such information to serve you advertising based on your location and interests. Your mobile device may allow you to opt out of the collection of precise location data, which applies to us and our advertising partners, as described below.

iOS – To disable the collection of Precise Location Data on iOS, you can disable Location Services for the relevant Simbi apps via the “Settings” > Privacy > Location Services menu. Then, select the relevant Simbi apps and change the status from “Allow Location Access” to “Never”. For additional information from Apple, go here https://support.apple.com/en-us/HT203033 .

Android (6.0/Marshmallow and later) – To disable the collection of Accurate Location Data on Android, you can disable Location Services for the relevant Simbi apps via the menu “Settings > Apps > [Simbi app] > Permissions > Location”. Then, disable the “Location” button.

 

  1. Privacy for minors

Our Services are aimed at a general audience, and not aimed at minors.

14.1 NDPA. Simbi does not intend to collect personal information from children under the age of 13 (“Children’s Personal Information”) in a manner that is not permitted by the Nigeria Data Privacy Act (“NDPA”). Its acronym in English). For some Services, we provide a version of the Service that does not collect Personal Information from a child, except as permitted by NDPA. If you believe that we have collected or are using Personal Information from a minor, or that your child under 13 years of age has misidentified your age, please contact us at help@simbi.ng and we will deactivate that account and we will delete the minor’s Personal Information associated with it to the extent required by NDPA.

14.2 European regulations for the protection of personal data. Likewise, Simbi does not intend to collect personal data from children under 16 years of age who access and/or use the Services. In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of these (General Regulation of data protection), if the user is under 16 years of age, they must have the consent of their legal guardian and only to the extent that the legal guardian agrees with this Privacy Policy to access and/or use the Services. If the user’s applicable national legislation allows it, the user under 16 years of age can access the service, provided that he or she is not less than 13 years of age.

For some Services, we provide a non-collecting version of the Service, that is, it does not collect Personal Information, for minors. If the minor user believes that we have collected or are using their Personal Information, or that their child under 16 years of age, or in your case 13 years of age, has misidentified their age, please contact us at help@simbi.ng and we will deactivate that account, and delete the child’s Personal Information associated with it.

 

  1. Applicable law and jurisdiction

15.1 Residents of Nigeria. For residents of Nigeria, these Privacy Policies will be governed by and construed in accordance with the laws of the Federal Republic of Nigeria and the laws of Ekiti State, without giving rise to any conflict of rules, laws or regulations. THESE POLICIES ARE A PART OF OUR TERMS OF SERVICE AND AS SUCH, ANY DISPUTE ARISING OUT OF OR RELATING TO THESE POLICIES OR YOUR USE OF THE SITE OR THE SERVICES IS SUBJECT TO BINDING ARBITRATION AND A WAIVER OF CLASS ACTION RIGHTS SUCH AS IT IS DETAILED IN SECTION 15 OF OUR TERMS OF SERVICE .

If any arbitration tribunal or other competent authority finds that any provision of these Privacy Policies is invalid or unenforceable, the remaining terms of these Privacy Policies will not be affected.

15.2 Users located in Europe – BINDING ARBITRATION: These provisions apply to the User when they access, download and use our Services in any Member State of the European Union, and to the extent that their jurisdiction permits. THESE POLICIES ARE A PART OF OUR TERMS OF SERVICE AND AS SUCH, ANY DISPUTE ARISING OUT OF OR RELATING TO THESE POLICIES OR YOUR USE OF THE SITE OR THE SERVICES IS SUBJECT TO BINDING ARBITRATION AS DETAILED IN SECTION 16 OF OUR TERMS FROM SERVICE .

If any arbitration tribunal or other competent authority finds that any provision of these Privacy Policies is invalid or unenforceable, the remaining terms of these Privacy Policies will not be affected.

15.3 Residents in other countries. This Privacy Policy will be governed and interpreted in accordance with the laws of the Federal Republic of Nigeria. All claims, legal proceedings or litigation arising from or in relation to these Policies, the Site or the Services, except as indicated in Clause 16 of our Terms of Services will be brought only before the relevant courts located in the city of Ado-Ekiti, Nigeria. The user consents to the jurisdiction and venue of such courts and waives any objection as to the inconvenience of the forum.

If any body of the Judiciary or other competent authority considers that any provision of these Privacy Policies is invalid or cannot be enforced, the remaining terms of these Privacy Policies will not be affected.

 

  1. Changes to Privacy Policies

The most current version of the policy will govern the use of the information and will be available at https://simbi.ng/privacy

Simbi may, from time to time and in its discretion, revise or modify this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform the user by posting the new revised Privacy Policy on the Site. Simbi may also, but is not obligated to, notify you of changes to the Privacy Policy by email to the email address associated with your account or by displaying a prominent notice on the Services.

If you object to any change in the Privacy Policy, the user must immediately cease using the Services and close related accounts. By continuing to access or use the Services after the changes become effective, you agree to be bound by the new updated Privacy Policy.

Notwithstanding the aforementioned, Simbi will review and update this Privacy Policy unless once a year.

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