IMPORTANT NOTICE ON CONSENT:
Kindly note that by accessing and/or installing our platform on your mobile phones, handheld devices, or any similar and or computerized gadget, you confirm that you have read, understood, and you accept the terms of this Policy set out hereunder. You also consent to the collection, use, storage, processing, and disclosure of your personal information in the manner now set out in this policy.
1. Dinesurf’s platform (platform) once you have accessed and/or installed a copy of the platform onto your mobile telephone, handheld device or any other computerized device (Device).
2. Any of the services accessible through the platform (Services) or other sites and media outlets of ours.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Kindly disregard as false any external messages, emails, or calls requesting your personal details in the name of Dinesurf, where such information has already been provided to Dinesurf upon signing up on our platform.
A. Information you now allow us to collect from you:
We may collect and process the following data about you:
a) Information you give us about you (Submitted information):
This may include information:
● Provided by filling in forms, logging on the platform or the platform Site or Service Sites (together Our Sites);
● provided by corresponding with our official customer help lines published in our website and other items of identification with the Dinesurf brand (for example, by phone call, e-mail or chat);
● provided by registering to use the platform Site, accessing or registering the platform, subscribing to any of our Services, searching for a hosted Services, sharing data via the platform functions, entering a competition, rating services, promotion, or survey, and reporting a problem with the platform, our Services, or any of Our Sites.
● This information may include your name, address, e-mail address, age, and phone number, age, username, password and other registration information, financial and credit information (including your credit/debit card), personal description.
b) Information you now allow us collect about you and your device:
When you send an email or other communications to us, we may retain those communications to process your inquiries, respond to your requests and improve our services.
Each time you visit our Site or use our platform, we may automatically have access to the following information (save for instances where any of the following information may be required to be processed by Dinesurf and in which case your express authorisation shall be required):
● technical information, including the type of mobile device you use, unique device identifiers (for example, your Device’s International Modern Equipment Identity (“IMEI”) or serial number), information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information);
● information stored on your device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content (Content Information);
● data from your use of any other third-party application on the Device or the Service Sites; and
● details of your use of any of our platforms or your visits to Our Service Sites; including, but not limited to, traffic data, location data, weblogs, and other communication data (Log Information).
c) Location information you now allow us collect:
Due to the nature of our services and some of our offerings(for example, identifying and suggesting resturants close to you and within your locality) we will also use GPS technology OR other location services to determine your current location. You can withdraw your consent to our collection,
processing or use of this information at any time by logging out and uninstalling the platform from your Device.
d) Information we receive from other sources (Third Party Information):
Due to the nature of the Services which we provide, we are required to work with some third parties (such as our partner restaurants, payment service providers and possibly mobile network providers) and we may receive information about you from them. By using our platform, you consent to us saving the information obtained from them.
B. Tracking and cookies:
We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the platform, Platform Site, or Service Sites. This helps us to provide you with a good experience when you use the platform or browse any of the Service Sites and also allows us to improve the platform and Our Service Sites.
C. How we use the information collected:
Information collected by us shall be generally used for the purpose of providing and improving the services available on the platform. We may disclose personal information that you submit to us to third-party such as (Payment service providers, our partner restaurants etc.) only where necessary for the purpose of providing our services and improving the same for your benefit. Provided that, and subject to compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, the anonymous cumulative/aggregate data obtained from our customers’ usage of our platform (not being personal and identifiable/traceable data) may be used by us for the purpose of industry and market analysis whether solely or in conjunction with third parties. You agree that third parties may request, and we can provide such information to them for this purpose whether or not for sufficient consideration. (For example, we may give out information in this manner: 25% of reservations made on high-end restaurants in Lagos are by persons under the age of 27).
D. Consent and Access Rights:
You hereby consent to the processing of your data by us. We shall obtain your consent for and to individual matters, where any document deals with different matters.
We can process your personal data in the absence of consent where:
a. processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract or for the provision of any of our products and services;
b. processing is necessary for compliance with a legal obligation to which you are subject;
c. processing is necessary in order to protect your vital interests or that of another natural person; and
d. processing is necessary for the performance of a task carried out in the public interest or in the exercise of the official public mandate vested in us.
If we intend to use your data for a purpose that is different from the purpose for which your data was obtained, we shall undertake to procure your consent prior to the use of your data for that other purpose. Provided that this requirement will not extend to matters covered by clause H below.
In the event of any arrangement whereby Dinesurf Limited is merged or combined with another entity (ies), sells or transfers all, or a portion of, its business or assets (including in the event of an internal or external restructuring, reorganization, dissolution or liquidation) to third parties, you hereby consent that your personal data held with Dinesurf Limited can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by Dinesurf Limited prior to such arrangement. Dinesurf Limited shall at all times ensure that you are notified when your personal data is intended to be transferred to third parties in the circumstances outlined in this clause.
No Consent shall be sought, given, or accepted in any circumstance that may engender direct or indirect unlawful propagation of atrocities, hate, child rights violation, criminal acts, and anti-social conducts. Also, kindly note that you reserve the right to request the modification or amendment of your personal data in our possession. Provided that in all cases of access or modification/amendment of personal information, we shall request sufficient identification, and utilize our identification policies to enable us to confirm that you are the owner of the data sought to be accessed or modified/amended.
E. Personal Data Protection Principles
When we process your personal data, we are guided by the following principles, which require personal data to be:
1. processed lawfully, fairly, in a transparent manner and with respect for the dignity of the human person.
2. collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.
3. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
4. accurate and where necessary kept up to date.
5. removed or not kept in a form that permits identification of data subject for longer than is necessary for the purposes for which the personal data is processed.
6. processed in a manner that ensures its security, using appropriate technical and organizational measures to protect against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
F. Third Party Access
We will only share personal information with other companies or individuals in the following limited circumstances:
a. We have obtained your consent, albeit subject to other parts of the policy on consent.
c. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request, (b) enforce applicable terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of its users or the public as required or permitted by law.
G. User Responsibility
You are required to familiarize yourself with this policy and to ensure that the information you provide to us is complete, accurate and up to date.
H. Disclosure of your information
We may disclose your personal information to third parties:
i. in the event that we sell or buy any business or assets, in which case we may disclose your personal data (such as Name, Phone number,
address, nationality, date of birth) to the prospective seller or buyer of such business or assets;
ii. if Dinesurf Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
iii. if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request (including but not limited to investigative request by legally authorized authorities); and/or
iv. in order to: enforce our User Terms of Service and other agreements or to investigate potential breaches; or for the purpose of publishing statistics relating to the use of the platform, in which case all information will be aggregated and made anonymous.
I. Where we store/transfer your personal data
The data that we collect from you may be transferred to, and/or stored at, a destination outside your country of origin or residence (as applicable).
By providing your consent to this policy, you also authorize us to transfer your Personal Data provided to us, to such other entities outside Nigeria connected with the Dinesurf Limited or related third parties, with the understanding that the data shall be used for the purpose stated in our contracts or terms of engagement with you and in line with the procedure for offshore transfer of personal data processed in Nigeria as set out under the Nigeria Data Protection Regulation 2019. Your Personal Data may be transferred outside Nigeria to any country outside Nigeria where a Dinesurf Limited entity is incorporated. The NDPR requires that the destinations must be explicitly mentioned (“Foreign Recipients”). We are required to inform you that the Foreign Recipients are on the White List of countries in the NDPR Implementation Framework 2019. What this means is that the NDPR considers that the Foreign Recipients have adequate data protection measures of a standard acceptable in Nigeria. By continuing to use our Services or Service Sites, you explicitly consent to the transfer of your Data to any of the Foreign Recipients mentioned above.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
J. Data Security
We implement and maintain appropriate safeguards to protect personal data, considering, in particular, the risks to you, presented by unauthorized or unlawful processing or accidental loss, destruction of, or damage to their personal data.
Safeguarding will include the use of encryption and pseudonymization where appropriate. It also includes protecting confidentiality (i.e. that only those who need to know and are authorized to use personal data have access to it), integrity and availability of the personal data. We regularly evaluate and test the effectiveness of those safeguards to ensure the security of our processing of personal data.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While we guarantee that we shall strive to protect the security of your information and are constantly reviewing and enhancing our information security measures on a best endeavor basis, we reasonably expect that there may be eventualities entirely out of our reasonable control and judgment. Dinesurf Limited therefore, accepts no liability for any direct or consequential damage or loss, however caused, in connection with transmission over the internet or electronic storage by or through
unauthorized, unlawful, and or unidentifiable persons/channels.
K. Links to third party sites
L. Your Rights
We will use your data for the purposes of compiling statistics relating to our user base and activity summary and any other product or service we provide and may
disclose such information to any third party for such purposes, provided that such information will always be anonymous.
We have put in place procedures to deal with any suspected personal data breach and will notify you of any personal data breach and let you know the steps we have taken to remedy the breach and the security measures we have applied to render your personal data unintelligible.
All suspected breaches of personal data will be remedied promptly or within a reasonable period of time from the date of the report of the breach to our official customer care contact channels (see below), and in any event not exceeding a period of one (1) month depending on the nature of the breach and the mechanisms required to be adopted for remediation.
If you know or suspect that a personal data breach has occurred, you should immediately contact the Dinesurf Limited team at (email).
Dinesurf Limited will not be responsible for any personal data breach which occurs as a result of:
(i.) any event which is beyond the control of Dinesurf Limited;
(ii.) any act or threats of terrorism;
(iii.) any act of God (including but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises Dinesurf Limited’s data protection measures;
(iv.) war, hostilities (whether war be declared or not), invasion, an act of foreign enemies, mobilization, requisition, or embargo;
(v.) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises Dinesurf Limited’s data protection measures;
(vi.) the transfer of your personal data to a third party on your instructions; and (vii.) the use of your personal data by a third party designated by you.
N. Data Retention
Dinesurf Limited shall retain and use your Data only as long as is necessary to provide our services to you, or as required to comply with legal or regulatory obligations, including under tax and security laws. We may retain your Data for a minimum of 5 years (or such longer period as may be necessary) even after we have received a request for deletion from you in order to comply with our regulatory obligations. We will retain your Data if there is an outstanding obligation or duty from you.
Notwithstanding, a request for erasure will automatically be denied in whole or in part, where it would adversely affect a constitutionally guaranteed right, contradict a legal obligation, act against the public interest in the area of public
health, act against the public interest in the area of scientific or historical research, or prohibit the establishment of a legal defense or exercise of other legal claims Dinesurf Limited or any legitimate third party. Where a request for erasure is denied, Dinesurf will provide to you the specific reason for denying the request as soon as possible but no later than one month after receiving the request for erasure.
Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, necessary or required by law, you will be notified on this platform, when next you log in to this platform or one of our Service Sites., The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the platform or the Services. In any event, by continuing to use the platform or any Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.
obliged to keep for administrative, legal, or security purposes.