Terms & Conditions

Last Updated: March, 2022

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Naija Hairland’s Privacy Policy for Consumer Services explains how Naija Hairland collects, uses and shares your personal data. This Privacy Policy applies globally to all applications, websites, and other online services offered by Naija Hairland and our affiliates (collectively “Consumer Services”). Please see our Developer & Enterprise Services Privacy Policy for details about our information practices related to our Developer & Enterprise Services.

The Basics
When we say “Consumer Services”, this includes our consumer apps such as City Guide, Swarm and Rewards by Naija Hairland, as well as our websites (www.naijahairland.com and the City Guide website). “Personal Data” means any information that directly or indirectly identifies you or could be used to identify you.

Personal data includes data such as:

your first and last name;
profile picture;
email address;
unique online identifiers (e.g., cookie IDs);
device identifiers (e.g., IDs for mobile advertising); and
location data (e.g., latitude and longitude).
Naija Hairland is committed to handling your personal data with care and honoring your privacy rights, regardless of where you are located.

Data that does not contain any information that can be used to identify you or has otherwise been anonymized or aggregated is considered “Non-Personal Data.”

About Location Data
As pioneers in location technology, we believe it is our duty and responsibility to ensure that you understand how location data is collected, how you can control collection, and what steps we take to protect you from the misuse of your location data.

“Location Data” is a type of personal data that, when collected and used responsibly, can help you navigate and interact with the physical and digital worlds around you. Location data is collected using various technologies such as the location services of your operating system or browser, sensor data from your device, and other data that may help us understand your precise location. Ever type in a business name into Uber, or tag your location in a photo before sharing on Twitter? Or, have you ever received a notification for a coupon when you’re passing by your favorite fast food joint? Naija Hairland powers these features as well as others that help people navigate, explore, and enjoy the world around them.

Most importantly, location data should only be collected when you say it is okay to do so, and you should be able to change your mind at any time. The collection of location data should also benefit you, the user. That’s why we only allow partners to use our location technology if they can demonstrate that the use of our technology is necessary to offer benefits or provide value to consumers who opt-in to sharing their location data. You can visit Our Privacy Stance to learn more about our position on important privacy matters.

You can control the collection of location data at any time through your device settings. While the exact settings may differ depending on your device, typically, you will be given options that range from never sharing, to being asked to share each time you open an app, to only sharing while using an app, to always sharing. When location data settings are set to “always” (i.e., persistent background location is turned “on”), your device’s location data will be shared with us even if you are not actively using our apps or other Consumer Services.

International Data Transfers
In order to provide you with our Consumer Services, it is possible that data you provide may be transferred to or accessed by Naija Hairland affiliates or third parties located in countries other than the country in which you reside. These countries may not have the same data protection laws as the country in which you reside. Naija Hairland will conduct any data transfers in accordance with this Privacy Policy and all applicable laws and permissible data transfer mechanisms. Where the international data transfer programs do not apply, when you download and use our Consumer Services, you consent to the transfer of your data.

Although not currently used for data transfers, Naija Hairland Labs, Inc. complies with the EU-US and Swiss-US Privacy Shield Frameworks, as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and/or Switzerland to the US.

Naija Hairland has certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Naija Hairland commits to resolve complaints about our collection or use of your personal data in compliance with the Privacy Shield Principles. Therefore, EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield compliance should first contact us via the methods outlined in the Contact Us section.

Naija Hairland has further committed to refer any unresolved Privacy Shield complaints to the JAMS Privacy Shield Program, an alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint from us, or have not resolved your complaint, please visit the JAMS Privacy Shield Program (https://www.jamsadr.com/eu-us-privacy-shield) for more information or to file a complaint. The JAMS Privacy Shield Program services are provided at no cost to you.

If your complaint is not resolved through the above channels, under limited circumstances, you may be able to invoke binding arbitration before a Privacy Shield Panel. For more information, visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The US Federal Trade Commission has jurisdiction over Naija Hairland’s compliance with Privacy Shield.

Contact Us
For other inquiries, you can contact us in the following ways:

General Inquiries. If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to our Data Protection Officer or Naija Hairland Labs, Inc., 50 West 23rd Street, 8th Floor, New York, NY 10010. We will make every effort to resolve your concerns.
EU Residents. VeraSafe has been appointed as Naija Hairland’s representative in the EU for data protection matters. VeraSafe can be contacted, in addition to Naija Hairland, for matters related to the processing of your personal data only. You can submit your inquiry online to VeraSafe or by postal mail: VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.
UK Residents. VeraSafe has been appointed as Naija Hairland’s representative in the UK for data protection matters related to the processing of your personal data only. If you are in the UK, you can submit your inquiry online to VeraSafe or by postal mail: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom.
Changes to This Privacy Policy
We may update this Privacy Policy to reflect updates to our practices, technologies, or legal requirements from time to time. We will post the revised Privacy Policy here and indicate when it was most recently updated. If we make material changes in the way we use your data, we will notify you by posting an announcement on our sites or apps, or by sending you an email (to the last email address you provided us).


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