IMPORTANT PRIVACY INFORMATION

When you access our website we automatically collect from your device referring URL, cookies, language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the website and to measure ads.

For improving the website and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Akamai, Amazon, Facebook, Google, Firebase, OneSignal, PubMatic, Sendios, Sentry, Criteo, LiveRamp. Therefore, some of the data is stored and processed on the servers of such third parties. This enables us to (1) analyze different interactions (what articles our users viewed); (2) serve and measure ads (and show them only to a particular group of users, for example, only to those, who clicked on certain type of advertisement).

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). If any questions will remain unanswered, please contact us at contactus@improvewithvictory.com.

PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use the website located at: https://www.improvewithvictory.com/ (the “Website”), any improvewithvictory.com mobile application (the “App”), and the services and products provided through it (together with the Website, the “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 18 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; (b) leave the Website and not access or use it; and (c) cancel any active email subscriptions.

“CCPA” means the California Consumer Privacy Act of 2018.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

TABLE OF CONTENTS

1. PERSONAL DATA CONTROLLER
2. CATEGORIES OF PERSONAL DATA WE COLLECT
3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
5. WITH WHOM WE SHARE YOUR PERSONAL DATA
6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
7. AGE LIMITATION
8. INTERNATIONAL DATA TRANSFERS
9. CHANGES TO THIS PRIVACY POLICY
10. FOR CALIFORNIA RESIDENTS
11. DATA RETENTION
12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
13. CONTACT US

1. PERSONAL DATA CONTROLLER

Naji.com Media Limited, a company registered under the laws of the Federal Republic of Nigeria, having its registered office at No 8 Adeleke Street, Off Allen Avenue, Ikeja, Lagos State, will be the controller of your personal data.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (for example, an email address). We also collect data automatically (for example, your IP address).

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Data you give us

You may be asked to provide us information about yourself when you use certain features of the Service. If you decide to subscribe for newsletter or to submit news to improvewithvictory, you may be asked to provide your email address.

You may use an opportunity to post comments on improvewithvictory. Comments are always public: they are available to everyone and may be displayed in search results on external search engines. You should be aware that any personal information you submit in comments can be read, collected and used by other users of the Service.

We may collect information you enter when clicking on third-party advertisements placed on the Service such as your email address, name and phone number.

Data provided by third parties

When you decide to log in the App using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID.

For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the Website on their Apps and Websites page.

Data we collect automatically:

1. Data about how you found us.

   We collect data about your referring URL (that is, the place on the Web where you were when you tapped/clicked on our ad).

2. Device and Location data.

   We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

3. Usage data.

   We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Website, how long you are on the Website, what articles you read, how many ads you watch.

4. Advertising IDs.

   We collect your Apple Identifier for Advertising (“IDFA”), Identifier for Vendor (“IDFV”) or Google Advertising ID (“AAID”) (depending on the operating system of your device) when you access our Website from a mobile device. You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

   We also use user ID modules, such as Criteo ID and Ramp ID, which are unique identifiers. The Criteo and the RampID privacy policies.

5. Cookies.

   A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising. Cookies set by us are called first-party cookies. We also use third party cookies, which are cookies from a domain different from the domain of our Website, for our advertising and marketing efforts.

   Cookies are used by us for the following purposes:

   • To speed up loading of pages.
   • To recognise and count the number of visitors, to know which pages are the most and least popular, and to see how visitors move around our Website when they are using it. As a result, we will be able to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
   • To make our Website and the advertising displayed on it more relevant to your interests.
   • To measure advertising performance.
   • To prevent fraudulent activity and improve security.
   • To personalize the content of the Website.
   • To analyze performance of the Website and fix bugs.

   Cookie data will be stored on your device and most of the times only for a limited time period. You can manage your cookies as set out in Clause 4.7 below.

3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

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To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.

We use Sentry as a cross-platform application monitoring, with a focus on error reporting, which helps us to monitor and fix bugs and crashes anywhere. To learn more, please visit Sentry’s Privacy Policy.

We use Akamai, which helps to implement a proprietary content delivery network (CDN) for end-users. To learn more, please visit Akamai’s Privacy Statement.

To customize your experience

We process your personal data to adjust the content of the Service and provide content tailored to your personal preferences.

To provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

To communicate with you regarding your use of our Service

We communicate with you, for example, by emails. These may include for example, emails with information about the Service. To opt out of receiving emails, you need to follow unsubscribe link located in the footer of the email or by contacting our support team at contactus@improvewithvictory.com.

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The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.

We use OneSignal Push Notification service, that is a mobile and web notifications service provided by OneSignal. Push notification allows us to send information to iOS and Android devices as well as to most web-browsers. Learn more about OneSignal’s approach to data in its Privacy Policy.

To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing. For example, if we discover that users are not interested in Gossip News, we may focus on improving it or replacing it with other news category.

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To analyse how visitors use our Website and to measure effectiveness of some ads we use Google Analytics, a web analysis program of Google. In order to provide us with analytics, Google Analytics places cookies on your device. On Google Analytics we get, in particular, aggregated information on the data you enter on our Website and users’ interactions within the Website. Google allows you to influence the collection and processing of information generated by the Google, in particular, by installing a browser plug-in, available here. You can read more about how Google uses information here.

We use Google Tag Manager to manage tags on the Website for conversion tracking and Website analytics.

To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Website. We may show you advertisements on our Website, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails or by contacting our support team at contactus@improvewithvictory.com.

We may also show you advertisements on the Website, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device or/and browser.

We use Sendios, which is a marketing personalization and retention platform, to deliver tailored email messages to our users.

To personalize our ads

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website, you might see ads of our products in your Facebook’s feed.

We may target advertising to you through a variety of ad networks and exchanges, using data from advertising technologies on and off of our Services like, unique cookie, or similar tracking technology, pixel, device identifiers, geolocation, operation system information, email.

We may also use data collected from a particular browser or device with another computer or device that is linked to the browser or device on which such data was collected.

Certain third parties, for example, PubMatic, a company that develops and implements online advertising software and strategies for the digital publishing and advertising industry, and its demand partners here, may use statistical identification or other non-cookie technologies (such as eTags and web or browser cache) on our Website, and browser settings that block cookies may have no effect on such technologies. Pubmatic Privacy Policy.

We use Criteo, which is an advertising platform, to serve our ads to audiences who have the same browsing habits as you. Criteo’s data collection and privacy policies can be found here.

When you use our website and enter your email address on our website (either to log in, or to sign up for a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR).

LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you.

Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time https://liveramp.com/opt_out/.”

How to opt out or influence personalized advertising

iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.

Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.

macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.

Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here.

To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

• Network Advertising Initiative – https://optout.networkadvertising.org/
• Digital Advertising Alliance – https://optout.aboutads.info/
• Digital Advertising Alliance (Canada) – https://youradchoices.ca/choices
• Digital Advertising Alliance (EU) – https://www.youronlinechoices.com/
• DAA AppChoices page – https://www.aboutads.info/appchoices

Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS

Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

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We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

We use Facebook pixel on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website (for example, clicked on one of the advertisements).

We also use Facebook Sharing SDK on the Website in order to make it easy for you to share content with your audience. If you use the Share Button you will open Facebook sharing dialogs. We won’t receive your personal data if you use sharing function.

Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

Google AdSense is an ad delivery service provided by Google. Google AdSense enables publishers to monetize content online. AdSense selects ads based on the content of the website and the website's audience. To know more about how Google processes your data, visit its Privacy Policy.

To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.

We process your personal data, in particular, under the following legal bases:

5. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• cloud storage providers (Amazon)
• data analytics providers (Facebook, Google)
• communication service providers (Sendios)
• marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Mailfire, Sendios, Sentry)

Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

6. HOW YOU CAN EXERCISE YOUR RIGHTS

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.

Deleting your personal data.You can request erasure of your personal data as permitted by law.

When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data.You can ask us to stop using all or some of your personal data or limit our use thereof.

To exercise any of your privacy rights, please send a request to contactus@improvewithvictory.com.

7. AGE LIMITATION

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.

8. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

10. FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires us to disclose what personal information we have collected, used, and shared over the last 12 months.

Section 2 describes the personal information we have collected about you, including the sources of that information. We collect this information for the purposes described in Section 3. We share this information as described in Section 5.

Under CCPA you as a California resident have the following rights, which you may exercise by yourself or you may designate an authorized agent to make these requests on your behalf:

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

To exercise any of your privacy rights, please send a request to contactus@improvewithvictory.com.

California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

To obtain this information from us, please send an email message to contactus@improvewithvictory.com which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

11. DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user's DNT preference. You can usually access your browser's DNT option in your browser's preferences.

We currently do not support “Do Not Track” requests because no DNT standard has been adopted.

Our third-party services may collect information about your and your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

13. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at contactus@improvewithvictory.com.

Effective as of: 22 April 2022