Privacy Policy – Neekuba Company Limited

Effective: October 15, 2020

This Privacy Policy applies to the information that Neekuba Company Limited (“Neekuba” “we”, “our”, “us”), collect through neekuba.com and other websites, online features, applications, products, services and widgets owned or controlled by Neekuba Company Limited or that post a link to this Privacy Policy (collectively, the “Site”) in order to demonstrate our firm commitment to privacy.

COLLECTION OF INFORMATION
Information You Provide

We may obtain information that you provide directly to us on the Sites and this includes, without limitation, all online and offline collections of all types of personal information, for example when you create an account, enter a sweepstakes on the Sites or on a third-party site, sign up for email communications, participate in a survey, contact customer service, engage in a promotion online or instore, or otherwise interact with the Sites. This information may include personal information, which is information that can be used to identify you individually. Personal information collected may include:

Contact information, such as name, address, email, mobile phone number, company/organization name, and/or job title
Unique identifiers and preference information such as username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, or navigation and clickstream behavior for online interactions
Resume including work history, professional qualifications, publications, awards, references, completed trainings, signature
Food restrictions, passport info for travel bookings or identification purposes, social security number (where required by law), bank account details, (emergency) contact persons, family information (where applicable and in accordance with local law)
Creditworthiness, VAT number, product, purchase information history, request documentation

Neekuba will retain and use the personal information collected for the above-mentioned processes and processing purposes in accordance with its obligations, including but not limited to legal, business and administrative obligations.

Information Collected Automatically

The Site is a general audience web site. In addition to any Personal Information or other information that you choose to submit to the Site, we and our third-party service providers, including any third-party content, advertising, and analytics providers, may use a variety of technologies that automatically or passively collect certain information about your use of the Site whenever you visit or interact with the Site (“Site Usage Information”). Site Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, the search terms you entered into a search engine that led you to our Site (if applicable), actions you take on the Site and all of the areas within our Site that you visit, and the time of day you visited the Site, among other information. Site Usage Information may also include the unique IP address or other unique identifiers (“Device Identifier”) for any computer, mobile phone, or other device (any, a “Device”) used to access the Sites. A Device Identifier is a unique value that is automatically assigned to your Device, so that our servers can identify your Device by its Device Identifier.

We may use Site Usage Information for a variety of purposes, including enhancing or otherwise improving the Sites and our products and services. We may associate Site Usage Information with you as a specific and identifiable person. When we do so, we treat the combined information as personal information.

The types of information we collect automatically when you visit the Sites may include IP addresses, device identifiers, browser characteristics, operating system details, language preferences, referring URLs, length of visit, and pages viewed. We may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from third parties. Information about your use of the Sites and other websites may be collected across time, devices, and websites for various purposes, including to associate different devices you use and to deliver relevant and/or retargeted content. If you choose not to provide the personal information we reasonably require, it may hinder Neekuba’s ability to provide the information or services you have requested.

USE OF INFORMATION

Neekuba may use information collected through the Sites, including Personal Information and Site Usage Information for various purposes including but not limited to: (1) allow you to use the Sites and to provide you related service, including responding to your questions and comments; (2) fulfill transactions and process your registration, orders and payments, including verifying the information you provide is accurate and active; (3) administer and develop our business relationship with you and the company you represent; (4) personalize your online experiences and tailor content, recommendations and offers we display to you on the Sites and elsewhere online; (5) provide you with information, products or services that you have requested or agreed to receive or that we otherwise believe will interest you, including, information and special offers from us, our advertisers, and our third party business partners; (6) conduct internal analyses, such as surveys and market research; (7) improve the Sites, our products and services and for internal business purposes; (8) assess your employment application for a position with Neekuba and prepare related governmental and internal statistics reports; (9) contact you with administrative communications and, in our discretion, changes to Site’s policies; (10) monitor and analyze trends, usage, and activities of visitors and users of the Sites; to comply with applicable laws, regulations, or legal process as well as industry standards and our company policies; (11) for purposes disclosed at the time you provide your information and as further described or permitted in this Privacy Policy; (12) ; prevent, investigate, identify, or take any other action with regard to any suspected or actual fraudulent or illegal activity or any activity that violates our policies; (13) to remember and restore your preferences when you return to the website; (14) to comply with applicable laws, regulations, or legal process as well as industry standards and our company policies or (15) otherwise with your consent.

Data Analytics

We may use certain third-party web analytics services, such as Google Analytics, to help us understand and analyze how visitors use the Sites and serve ads on our behalf across the Internet. For example, if you clicked on one of our advertisements that led you to the Site, our service provider(s) may be able to tell us information about your interaction, such as, but not limited to: which advertisement you clicked on, where you were viewing the advertisement, how often you viewed or clicked on it, and so forth. In connection with serving content and providing analytics and advertisement services, third parties may collect certain information about your visits to the Sites or other websites. Some of these parties may collect personal information when you visit the Sites or other websites or services. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your Device Identifier, Site Usage Information, and related information about you. Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, and to conduct research regarding the usefulness of certain advertisements to you. We may share Device Identifier and Site Usage Information about visitors with third-party advertising companies, analytics providers, and other vendors for similar purposes.

In addition to information you submit through the Sites, we may collect certain information using automated tools, such as cookies. “Cookies” are small data files stored by your web browser on your device. Cookies may allow a website to recognize a user’s device, record user preferences, track the pages a user clicks on while visiting the website, and identify the website visited immediately beforehand. Using cookies and pixel tags (also known as web beacons), these third-party analytics services collect information about your visits to the Sites and other web sites in order to deliver advertisements that may be of particular interest to you. Most web browsers accept cookies and pixel tags by default, but you may be able to adjust your browser settings to remove or reject cookies. Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, the Sites are not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit http://www.allaboutdnt.com/. . Please note that blocking cookies may affect the availability and functionality of the Sites and other websites. Also, disabling cookies may invalidate opt outs that use cookies to recognize devices that have opted out.

III. DISCLOSURE OF INFORMATION

Certain content on the Sites may be hosted and served by third parties and the Sites may contain links to third-party websites that does not control. The Site may also contain certain third-party content or applications. These links and applications may use a Neekuba logo as part of a co-branding agreement. In addition, Neekuba widgets or other Neekuba content may be included on web pages and websites that are not associated with Neekuba and over which we have no control. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services. Neekuba is not responsible for the privacy practices employed by any third party.

Neekuba may share information, including personal information, as applicable, among its subsidiaries and affiliates, primarily for business and operational purposes. Neekuba may also disclose and transfer your information, including Personal Information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) if Neekuba(or any of its affiliated subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of our ownership interests, assets, or both, or other corporate change, including, without limitation, during the course of any due diligence process.

Neekuba may also share non-personally identifiable information, such as aggregated user statistics, with third parties in our discretion. We do not share your personal information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in or opt-out of such sharing. We may share the information we have collected about you, including personal information, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy. We may also collect demographic information (such as, but not limited to, your age, occupation, postal code, or similar information), certain information about your preferences and interests, customer questions and support information, and other information collected through surveys, chat features, and polls made available on the Sites. If we combine these types of other information about you with personal information, we will treat the combined information as personal information under this Privacy Policy.

You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your personal information shared, your personal information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an interactive feature or third-party application, that we share information about you with a third party and we will typically do so under those circumstances.

We may use third party service providers to help us operate our business and the Sites or administer activities on our behalf. We may share information with third parties so that they may provide services to you, Neekuba, and the Sites. Examples include conducting website usage analysis, sending e-mail or other communications on our behalf, providing sales and marketing assistance, or performing other administrative or support services. For instance, if you participate in a sweepstake, game, or loyalty program resulting in a prize or award, we will share your information with our games and merchandise fulfillment and management agencies. When we do so, the information is only to be used to provide services or help us provide services. Third-party systems used to deliver services to you may retain your information for a period of time after the services are provided.

Personal information of any individual user may be shared with other companies outside Kellogg Company: (i) as permitted by law; (ii) in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions; (iii) where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process; or (iv) to enforce our policies, or to protect legal rights, propriety, or safety. (v) to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation (including to meet national security or law enforcement requirements); (iii) to enforce applicable Sites terms and policies; or (iv) to respond to an emergency or otherwise to protect the safety, rights, property, or security of Kellogg Company, third parties, Site visitors, or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with a court order or law enforcement agencies when legally compelled to do so.

USER-GENERATED CONTENT FUNCTIONS

The Site may provide you the opportunity to participate and post content publicly through interactive features. You may choose, through such features or otherwise, to submit or post reviews, comments, or suggestions related to Neekuba services, or post free-form comments (collectively, “User Generated Content”). Please note that certain information, such as your name and state of residence, and a link to any website URL you provide may be publicly displayed on the Sites along with your User Content. Note that any User Generated Content you post is public — others will have access to your User Content and may read it, see it, use it, and/or share it with third parties. If you choose to voluntarily disclose personal information in your User Content, that information will be considered public information and the protections of this Privacy Policy will not apply. We or others may store, display, reproduce, publish, distribute, or otherwise use User-Generated Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User-Generated Content and may have the ability to share it with third parties.

If you submit User Generated Content, it may be published online or offline (including on the Site, on-air, in a DVD, or any other format currently existing or later developed). In addition, we may use your User Generated Content and any excerpt from your User Generated Content in connection with our advertising, marketing, publicity, and promotional activities, and you hereby grant us a worldwide, perpetual, royalty-free, fully paid right and license to copy, display, distribute, modify and publicly perform, as applicable, the User Generated Content for such purposes. However, Kellogg will not publish your e-mail address with these comments. Please note that we do not control who will have access to the information that you choose to make available to others and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Sites or what others do with information you share with them on the Sites. We are not responsible for the accuracy, use, or misuse of any User-Generated Content that you disclose or receive from third parties through the Sites.

SWEEPSTAKES, CONTESTS ETC.

We may operate sweepstakes, contests, raffles, and similar promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require registration or submitting personal information. If you choose to participate in a Promotion, your personal information may be disclosed to third parties as described in the terms applicable to that Promotion. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list. Insofar as the terms applicable to a particular Promotion conflict with this Privacy Policy, the terms applicable to the Promotion shall control.

LINKS AND THIRD PARTIES’ PRIVACY PRACTICES

The Sites may contain links to other websites that are not operated by Neekuba for your convenience and information. This Privacy Policy does not apply to those websites, which may have their own privacy policies or notices that you should review to understand how they may use or disclose your personal information. Neekuba is not responsible for the content or privacy practices of any linked websites that we do not control.

We may also receive information about you from third parties. For example, if you are on another website that provides information about service providers like Neekuba and you request to receive information from Neekuba that website will forward your contact and other information to us so that we may contact you as requested. Third parties may also provide information about you in connection with a marketing arrangement we may have with those third parties.

We may also supplement the information we collect with outside records from third parties in order to provide you with the information, goods, or services you have requested to enhance our ability to serve you, to tailor our content to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from those other outside sources with information we collect through the Sites. In those cases, we will apply this Privacy Policy to the combined information.

VII. SECURITY

We strive to maintain appropriate administrative, technical, and physical safeguards that are designed to help protect personal information collected or received through the Sites. Although we follow reasonable procedures to safeguard information, no data transmission over the Internet, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect. You use our Site and provide us with your information at your own risk. Our employees are required to keep information covered by this Privacy Policy confidential – unless disclosure is authorized in this Privacy Policy, or by you. Neekuba will retain your personal information for as long as reasonably necessary to comply with legal obligations or for no longer as required for legitimate business purposes.

VIII. CHOICE

You can correct, make changes, update or otherwise modify some of the personal information you have provided to us several ways. If you are a customer, you can update your personal information (including opting out) by logging into any feature provided by the Site’s platform and changing your profile in the system or use the Contact Us form on the Sites. You may also contact us via telephone at +233 500 198 119 or email at business@neekuba.com and request that we change your information. Neekuba also gives you convenient methods for removing your information from our database so as not to receive future communications or to close your account via any of the methods detailed herein.

Neekuba will make good faith efforts to make requested changes in our active databases as soon as reasonably practicable. In addition, to the extent applicable, Neekuba will comply with the exercise of data subject rights under the General Data Protection Regulation. Also, if you have made any public postings, including User Content, these communications generally will not be removed. Users who receive a newsletter or other similar e-mails from us and who wish to remove themselves from the mailing list (i.e. opt out) can do so by following the link provided in an e-mail received. The Site may also offer an online mechanism for changing your preferences. However, please note that regardless of your opt-in preferences, we reserve the right to send you certain communications relating to your use of our Site, service announcements, notices of changes to this Privacy Policy, or similar administrative or transactional messages, and these transactional account messages. If you opt to receive communications from multiple brands within the Kellogg family of companies and then change your election, you may need to opt-out individually from each of the brands to which you agreed to receive brand-specific communications.

You may request details of personal data which we hold about you. If you believe that any personal information we are holding about you is incorrect, incomplete, you would like to object to the collection or use of your information, or you would like to have your information erased, please contact us as soon as possible, at the address above. We will promptly correct any personal information found to be incorrect.

CHILDREN’S PRIVACY

Our Site is not intended for, nor targeted to, children under 13, and we do not knowingly request or collect personal information from any person under 13 years of age through the Site. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law. Neekuba will not collect personal information from anyone we know to be under the age of 13 without the prior, verifiable consent from his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

APPLYING FOR A JOB THROUGH OUR SITE

If you apply for a job through the Site, we, or a human resources company assisting us, may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Government of Ghana, and similar state and local regulatory agencies. Providing self-identifying information is voluntary, but if you do provide us with that information, we may submit it to the relevant state institutions in Ghana, and similar state and local regulatory agencies for business-related purposes, including responding to information requests, fulfilling regulatory reporting requirements, and defending against employment related complaints.

UPDATES TO THIS PRIVACY POLICY

Neekuba reserves the right to make changes in this Privacy Policy. If material changes are made in how personal information is collected, used, disclosed or otherwise processed, this Privacy Policy will be updated and notices will be provided when/where appropriate. These changes will take effect immediately upon posting. For your convenience, the last revised date of the current Privacy Policy will be posted at the top of this page. By continuing to use the Site following such changes, you will be deemed to have agreed to such changes. Where required to do so by law, Neekuba may seek your prior consent to any material changes we make to this Privacy Policy.

XII. CONTACTING NEEKUBA COMPANY LIMITED

If you have any questions or comments about Neekuba’s Privacy Policy, regarding your personal information, the ways in which we collect and use your personal information or your choices and rights regarding such use, please contact us at business@neekuba.com.