AnyworkX Privacy Policy

Welcome to AnyworkX’s privacy policy (“Privacy Policy” or “Policy”). Please take time to read it.

AnyworkX is a product and registered trade name and trade mark of X-agon Digital Solutions Limited. X-agon Digital Solutions Limited and its product AnyworkX as well as affiliates (collectively, “X-agon”, “we” or “us”) are engaged in the business of providing digital solutions to facilitate connections between customers that seek specific services and service providers that offer these services. This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with us when you access, use, or otherwise interact with our website available at https://www.anyworkx.africa/ or our mobile applications ‘AnyworkX Customer App and AnyworkX Vendor App’ (collectively, “Platform”) or when using the products or services offered by X-agon through the Platform (collectively referred to as the "Services"). In this Policy, the services offered to you by service providers on or through the Platform are referred to as “Professional Services”.

At X-agon, we are committed to protecting your personal data and respecting your privacy. In order to provide you with access to the Services or the Professional Services, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you.

Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms and Conditions, available at https://www.anyworkx.africa/terms (“Terms”). Please read this Policy in consonance with the Terms.

By using the Services, you confirm that you have read and agree to be bound by this Policy and consent to the processing activities described under this Policy.

Privacy Policy

We appreciate that you trust us with your information, and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in simple language, keeping legal and technical terms to the barest minimum.

This Privacy Policy applies from 1st April 2023 and may be reviewed from time to time. The Table of Contents in our Policy provides a concise overview of the sections covered and facilitates easy navigation through our data protection guidelines:

Please refer to Section 1 to understand how the terms of this Policy apply to you.

Who we are:The duly incorporated company responsible for your information under this Privacy Policy (the “data controller”) is: X-agon Digital Solutions Limited. AnyworkX is a product, trade name and trademark of the company. The registered address of the company is Plot 1390, Tiamiyu Savage Street, Victoria Island, Lagos, Nigeria and the principal place of business at 12, Algiers Street, Wuse Zone 5, Abuja, Federal Capital Territory, Nigeria.

1. BACKGROUND AND KEY INFORMATION

  1. How this Policy applies: This Policy applies to individuals who access or use the Services or otherwise avail the Professional Services. For the avoidance of doubt, references to “you” across this Policy are to an end user that uses the Platform. By using the Platform, you consent to the collection, storage, usage, and disclosure of your personal data, as described in and collected by us in accordance with this Policy.
  2. Review and Updates: We regularly review and update our Privacy Policy, and we request you to regularly review this Policy. It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
  3. Third-Party Services: The Platform may include links to third-party websites, plug-ins, services, and applications (“Third-Party Services”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We neither control nor endorse these Third-Party Services and are not responsible for their privacy statements. When you leave the Platform or access third-party links through the Platform, we encourage you to read the privacy policy of such third-party service providers.

2. Our commitment to you

At AnyworkX, your privacy, safety and security are top priorities. They are at the core of the way we designed and built and update the App that you will love, and which will become an essential App. Our desire is for you to fully trust the App and focus on using it to ease the search for service providers.

We appreciate that you put your trust in us when you provide us with your information, and we don’t take this lightly.

Our commitment to privacy: We have designed AnyworkX with your privacy, safety, and security in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy, safety and security.

Our commitment to transparency:We have made conscious effort to write our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices. We fully understand that insufficient information and overly complicated language are common in privacy policies. We have tried as much as possible to simplify it for you.

Our commitment to security: We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

3. WHO WE ARE

The company responsible for your information under this Privacy Policy (the “data controller”) is: X-agon Digital Solutions Limited. AnyworkX is a product and trademark of the company. The registered address of the company is Plot 1390, Tiamiyu Savage Street, Victoria Island, Lagos, Nigeria and the principal place of business at 12, Algiers Street, Wuse Zone 5, Abuja, Federal Capital Territory, Nigeria.

4. PERSONAL DATA THAT WE COLLECT

  1. We collect different types of personal data about you. This includes, but is not limited to:
    1. Contact Data, such as your mailing or home address, location, email addresses, and mobile numbers
    2. Identity and Profile Data, such as your name, username or similar identifiers, photographs, and gender.
    3. Biometric Data, such as fingerprint and facial recognition, for identity verification and security purposes.
    4. Personal Identification Number (PIN) that you set up during the registration process.
    5. Marketing and Communications Data, such as your address, email address, information posted in service requests, offers, wants, feedback, comments, pictures and discussions in our blog and chat boxes, responses to user surveys and polls, your preferences in receiving marketing communications from us and our third parties, and your communication preferences. We also collect your chat and call records when you communicate with service professionals through the Platform.
    6. Technical Data, which includes your IP address, browser type, internet service provider, details of operating system, access time, page views, device ID, device type, frequency of visiting our website and use of the Platform , website, and mobile application activity, clicks, date and time stamps, location data, and other technology on the devices that you use to access the Platform.
    7. Transaction Data, such as details of the Services or Professional Services you have availed, a limited portion of your credit or debit card details for tracking transactions that are provided to us by payment processors, and UPI IDs for processing payments.
    8. Usage Data, which includes information about how you use the Services and Professional Services, your activity on the Platform, booking history, user taps and clicks, user interests, time spent on the Platform, details about user journey on the mobile application, and page views.
  2. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
  3. What happens if I refuse to provide my personal data?

Where we need to collect personal data by law, or under the terms of a contract (such as the Terms), and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with the Services). In this case, we may have to cancel or limit your access to the Services.

Information you give us: You choose to give us this information when using our services. This includes:

  1. When you create an account, you provide us with at least your phone number and email address, National Identity Number (NIN), as well as some basic details necessary for us to verify your identity, ensure that fake profiles are not used and for the service to work. The information you provide us also include your gender, date of birth and a description of what you do.
  2. When you complete your profile, you have the option to share your location with us. Where you provide such elements to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on your bio and your job experience, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album.
  3. When you transact a business or make a firm order for a service or fund your wallet to make payment for identity verification or services or withdraw from your wallet to your bank account, you provide us with information related to the transaction and our payment processors captures other information such as your bank details, debit or credit card number or other financial information.
  4. When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials. When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
  5. When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
  6. If you contact our customer care team, we collect the information you give us during the interaction.
  7. If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf, in order to complete your request.



Information we receive from others: In addition to the information you may provide us directly, we receive information about you from others, including:

  1. Other Platform Users: Other users may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.
  2. Social media: You are required to share information with us about your social media account as part of our verification process. We may also share information with us about your social media account if you decide to create and log in to your AnyworkX account via your social media or other account (e.g. Facebook, Google or Apple), or to upload onto our services information such as photos from any of your social media accounts (e.g. Instagram or Spotify).
  3. Affiliates: AnyworkX considers the safety and security of its users a top priority. If you were banned from any service X-agon Digital Solutions Limited has affiliation with, your information can be shared with us to allow us to take necessary actions, including closing your account or preventing you from creating an account on our services.
  4. Other partners: We may receive information about you from our strategic partners, which include law enforcement agencies, the judiciary, human right groups, media publications, or where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties, as part of our efforts to ensure our users’ safety and security.
Information generated or automatically collected when you use our services:

When you use our services, this generates technical data about which features you have used, how you have used them and the devices you use to access our services. See below for more details.

Information collected by cookies and similar technologies:

We use and may allow others to use cookies and similar technologies (e.g. web beacons, pixels, SDKs) to recognise you and/or your device(s). You may read our Cookie Policy for more information on why we use them and how you can better control their use.

Other information with your consent:
  • Photo verification data: The safety and security of users are very important to us. This is achieved in part through our photo verification feature. If you choose to participate in our photo verification feature, we collect your face geometry data, which may be considered biometric data in some jurisdictions, to verify that you are the real you. You can learn more about photo verification and how we process your face geometry data.
  • Other information: We may collect other information with your permission, such as photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our services).

    • 5. How We Use Information

    The main reason we use your information is to ensure the safety and security of users and also deliver and improve our services. It is important to emphasise that we use your information to help keep you and AnyworkX clan safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

    A. To administer your account and provide our services to you.

    B. To help you connect with other users.

    C. To provide new AnyworkX services to you.

    D. To provide offers and operate advertising and marketing campaigns.

    E. To improve our services and develop new ones.

    F. To prevent, detect and fight fraud and other illegal or unauthorised activities.

    G. To ensure legal compliance.

    For information on how we process personal information through profiling and automated decision-making, please see our FAQ.

    To process your information as described in this Privacy Policy, we rely on the following legal bases:

    Provide our service to you: The reason we process your information for purposes A, B and C above is to perform the contract that you have with us. For instance, as you go about using our service to make meaningful connections on your service and business needs, we use your information to maintain your account and your profile, make it viewable to other users and recommend other users to you, and to otherwise provide our free and paid features to you and other users.

    Legitimate interests: We process your information for purposes D, E and F above, based on our legitimate interest. For instance, we analyse users’ behaviour on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our users safe, and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.

    Comply with applicable laws and regulations: We process your information for purpose G above where it is necessary for us to comply with applicable laws and regulations and provide evidence on our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax, and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents users give us and decisions they may have taken to opt out of a given feature or processing.

    Consent: If you choose to provide us with information that may be considered 'special' or 'sensitive' in certain jurisdictions, such as your sexual orientation, you are consenting to our processing of that information in accordance with this

    Privacy Policy: From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered 'special' or 'sensitive'). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

    6. New uses of personal information

    From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

    7. How we share information

    Since our goal is to help you make seamless connection for your business and service needs, the major aspect of sharing of users’ information is, of course, with other users. We also share some types of user information with external service providers and partners who assist us in operating the services, with other X-agon Digital Solutions Ltd for specified reasons as laid out below and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

    With other users

    You share information with other users when you voluntarily disclose your information on the service (including your public profile). Please be careful with your information, and make sure that the content you share are things you are comfortable with to be in a public domain. You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information, and make sure that the content you share are things you are comfortable with to be in a public domain. You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information, and make sure that the content you share are things you are comfortable to be in the public domain.

    If you choose to limit the audience for all or part of your profile, or for certain content or information about you, then it will be visible according to your settings.

    If someone submits a report involving you (such as a claim that you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.

    With our service providers and partners

    We use vendors to help us operate, distribute, market, and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with vendors who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising vendors.

    We follow a strict vetting process prior to engaging any vendor or working with any partner. Our vendors and partners must agree to strict confidentiality obligations.

    With our affiliates

    We are part of the X-agon Digital Solutions Limited family of businesses. We share your information with affiliates for limited legitimate purposes as laid out below:

    For corporate transactions

    We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.

    With law enforcement/when required by law

    We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

    To enforce legal rights

    We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

    With your consent or at your request

    We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

    We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioural data, location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other businesses under X-agon Digital Solutions Limited and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyse and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy

    8. Cross-border data transfers

    Sharing of information laid out in Section 5 involves cross-border data transfers to other jurisdictions that may have different laws about data processing. When we transfer personal information outside of Nigeria, we use standard contract clauses (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data) or other appropriate transfer mechanism.

    9. Your rights and choices

    We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

    Access/update tools in the service: Tools and account settings can help you access, rectify or remove information that you provided to us and that is associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help.

    Device permissions: Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality and you may not be able to use the App maximally.

    Uninstall: You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Reuser that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.

    Account closure: You can close your account by using the corresponding functionality directly on the service.

    We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:

    Access/know: You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. You can exercise your right to access directly within the service by putting in a request.

    Delete/erase: You may request that we delete the personal information we keep about you. You can exercise your right to delete by submitting a request.

    Correct/rectify/update: You can correct most information you provided to us by editing your profile directly in the service. If you believe the information that we hold about you is inaccurate, you may contact us to rectify it.

    Object/restrict: You may also have the right to object to or request that we restrict certain processing. To do so, please contact us.

    For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another user, such as a copy of any messages you received from them through our service, the other user will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. We may also not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and, thus, cannot ensure that you are 18 years of age or older.

    You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. There are data protection regulators in many jurisdictions. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.

    10. How long we retain your information

    We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 4) and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other users. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:

    To protect the safety and security of our users, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest, as well as that of potential third-party victims.

    Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:

    a. We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data”/logs for one year to comply with legal data retention obligations. We also keep records of consents users give us for five years to evidence our compliance with applicable law.

    b. We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defence of legal claims, and data necessary to prevent users who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our users.

    c. Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).

    11. No children allowed

    Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a user is under the age of 18, please use the reporting mechanism available on the service.

    12. Job candidates, CONTRACTORS, and vendor representatives

    We process the personal information of our job candidates, contractors, and vendor representatives, as part of our recruitment and talent management operations and our management of the services that contractors and vendors provide to us. If you are a job candidate, contractor or vendor representative of ours, certain relevant terms of this Privacy Policy apply to our processing of your personal information, including the sections of this Privacy Policy that discuss the entity that is responsible for the processing of your personal information, transfers of personal information, rights you may have under applicable law, and how to contact us.

    If you are a job applicant, the personal information we process about you may vary depending on the job you seek, but, typically, includes what you provide to us as part of your job application, as well as professional qualifications, background, and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. For contractors and vendor representatives, we may process identification information and work-related information, as necessary to manage our relationship with you and your employer, which is necessary for the performance of the services agreement, and to establish, exercise or defend potential legal claims. We may share personal information with service providers that assist us with recruitment and technical data processing operations, as well as with Match Group companies (for instance, if you have a business relationship with employees of an affiliate). We keep your personal information only as long as is necessary for those purposes.

    13. Privacy Policy changes

    Because we are always seeking new and innovative ways to make our App, and the clan we serve, safer and secure, help you build seamless connections and strive to make sure explanations about our data practices remain up to date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

    14. How to contact us

    If you have any questions about this Policy, how we process or handle your personal data, or otherwise, you may reach out to us, with your queries, grievances, feedback, and comments at privacy@anyworkx.africa or contact our Legal & Compliance Officer whose contact details are provided below:

    Name: Precious Ebubechi Nze; Designation: Legal & Compliance Officer Email: enze@x-agon.africa
    By Post
    Legal & Compliance Officer X-agon Digital Solutions Limited 12, Algiers Street, Wuse Zone 5, Abuja, Federal Capital Territory, Nigeria.



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