Privacy Policy Statement

The Privacy Policy governs the use of the services provided by Nnenu Limited (hereinafter also referred to as "we", "our" or "us"), via various electronic platforms such as the Nnenu mobile application (the "Product"). The Product and the services offered and/or provided thereon shall collectively hereinafter be referred to as the ("Services").

By using the Services in any manner (whether as a registered user or otherwise), you agree that you have read, agree and accept the terms stated in this Privacy Policy.

We reserve the right to modify this Privacy Policy, without notice, at any time. You understand that your continued use of the Services after this Privacy Policy has been modified constitutes your acceptance of the Privacy Policy as amended. For the avoidance of doubt, this Privacy Policy shall also apply to our Advertisers (as defined below), as users of the Services and/or Account (as defined below) holders.

We are committed to protecting your privacy, and we hope that this Privacy Policy demonstrates our commitment to fair information practices, and that this Privacy Policy gives confidence to use the Services.

In Nnenu app, we must process information about you. The type of information that we collect depends on how you use our Products.

We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content and message or communicate with others. This can include information in or about the content that you provide (e.g. metadata), such as the location of a photo or the date a file was created. Our systems automatically process content and communications that you and others provide to analyze context and what's in them for the purposes of generating information matching your location and preferences.

We collect information about the people, accounts, hashtags, and Pages that you are connected to and how you interact with them across our Products, such as people you communicate with the most or groups that you are part of. We also collect contact information if you choose to upload, sync, or import it from a device (such as an address book or call log or SMS log history), which we use for things such as helping you and others find people you may know and for the other purposes listed below.

We collect information about how you use our Products, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Products, and what posts, videos and other content you view on our Products. We also collect information about how you use features such as our camera.

We also receive and analyze content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you or upload, sync or import your contact information.

As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use. For example, we use information collected about your use of our Products on your phone to better personalise the content (including ads) or features that you see when you use our Products on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad that we showed you on your phone on a different device. Information we obtain from these devices includes:

information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.

information about operations and behaviours performed on the device, such as whether a window is in the foreground or background, or mouse movements (which can help distinguish humans from bots).

unique identifiers, device IDs and other identifiers, such as from games, apps or accounts that you use, and Family Device IDs (or other identifiers unique to Nnenu product associated with the same device or account).

Bluetooth signals, information about nearby Wi-Fi access points, beacons and mobile phone masts.

information you allow us to receive through device settings that you turn on, such as access to your GPS location, camera or photos.

information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed.

data from cookies stored on your device, including cookie IDs and settings.

Advertisers, app developers and publishers can send us information through Nnenu tools that they use, including our social plug-ins (such as the Like button), Nnenu app Login, our APIs and SDKs. These partners provide information about your activities off of our Products – including information about your device, websites you visit, purchases you make, the ads you see and how you use their services – whether or not you have an account or are logged in to our Products.

We use the information that we have (subject to choices you make) as described below and to provide and support the Nnenu App. Here's how:

We use the information that we have to deliver our Products, including to personalise features and content (including your ads and Nnenu Map) and make suggestions for you (such as information, groups or events that you may be interested in or topics that you may want to follow) on Nnenu App. To create personalised Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data that we collect and learn from you and others; how you use and interact with our Products; and the people, places or things that you're connected to and interested in on and off our Products.

We use location-related information – such as your current location, where you live, the places you like to go, and the businesses and people you're near – to provide, personalise and improve our Products, including ads, for you and others. Location-related information can be based on things such as precise device location (if you've allowed us to collect it), IP addresses.

We use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.

We use the information we have about you – including information about your interests, actions and connections – to select and personalise ads, offers and other sponsored content that we show you.

We use the information we have (including your activity off our Products, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps and services.

We use the information that we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of Nnenu Products. For example, we use data that we have to investigate suspicious activity or violations of our Terms or Policies.

We use the information that we have to send you marketing communications, communicate with you about our Products and let you know about our Policies and Terms. We also use your information to respond to you when you contact us.

We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

Your information is shared with others in the following ways:

People and accounts that you share and communicate with When you share and communicate using our Products, any people and businesses can see the content you send. Public information can be seen by anyone, on or off our Product, including if they don't have an account. This includes your Nnenu app username, any information you share with a public audience, information in your public profile on Nnenu, and content you. You, other people using Nnenu product and we can provide access to or send public information to anyone on or off our Products, in search results or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs and offline media such as TV, and by apps, websites and other services that integrate with our Products.

You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience that you shared with. For example, when you share a post to specific friends, they can download, screenshot or reshare that content to others across or off our Products. Also, when you comment on someone else's post or react to their content, your comment or reaction will be visible to anyone who can see the other person's content, and that person will be able to change the audience later. People can also use our Products to create and share content about you with the audience they choose.

If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.

We may transfer information about you to another company in connection with a merger, sale or acquisition. In this event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy. We do not, sell, rent or trade your information and Personal Data with any third parties for their marketing purposes, without your explicit consent. We reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on the Nnenu product. We share feedback provided about you by our Partners in order to ensure the best possible experience for all parties involved. We also share certain categories of information we collect from you and about you from our affiliates and Partners in the ways described in this Privacy Policy. We may also share your information, Personal Data and Traffic Data with our affiliates and Partners and other third parties who assist us by performing core services (such as business consulting and continuity planning, marketing, promotion, data analytics, data processing, hosting, storage and security) and/or by making certain Services available to our users. These affiliates, Partners and other third parties are bound by the same and/or are required to uphold the comparable standards of security and confidentiality as particularized in the terms of this Privacy Policy, and they will use your contact data and other personal information to carry out their obligations to and to provide you with the related Services. For the avoidance of doubt, you agree that Partners may (with our prior written consent) use your information or Personal Data for their own marketing and/or promotional efforts. The Partners’ use of your information or Personal Data shall, at all times, still be compliant with the relevant and applicable local laws.

We work with third-party partners who help us provide and improve our Products or who use Nnneu Business Tools to grow their businesses, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties that we share information with:

We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, listings, videos (if applicable) and other content on and off the Nnenu Products.

We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general demographic and interest information for advertisers (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Madrid and likes software engineering) to help them better understand their audience. We also confirm which ads led you to make a purchase or take an action with an advertiser.

When you subscribe to receive premium content, or buy something from a seller in our Products, the content creator or seller can receive your public information and other information that you share with them, as well as the information needed to complete the transaction, including shipping and contact details.

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analysing how our Products are used, providing customer service, facilitating payments (if applicable) or conducting surveys.

We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that supports our business or mission and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

We share information with law enforcement or in response to legal requests in the circumstances outlined below.

We provide you with the ability to access, rectify, port and delete your data. We store data until it is no longer necessary to provide our services and Nnenu Product, or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete things that you have posted, such as your photos and status updates, and you won't be able to recover this information later. Information that others have shared about you isn't part of your account and won't be deleted.

We access, preserve and share your information with regulators, law enforcement or others:

• In response to a legal request (e.g. a search warrant, court order or subpoena) if we have a good-faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of Hong Kong when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction and is consistent with internationally recognised standards.

• When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorised use of the Products, breaches of our Terms or Policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.

Information that we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for term breaches for at least a year to prevent repeat abuse or other term breaches.

We share information globally, both internally within Nnenu, and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in Hong Kong or other countries outside of where you live for the purposes as described in this Policy. These data transfers are necessary to provide the services set forth in the Nnenu and to globally operate and provide our Products to you. We utilize standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to Hong Kong and other countries.

We'll notify you before we make changes to this Policy and give you the opportunity to review the revised Policy before you choose to continue using our Products.

If you have questions about this policy, you can contact us at sarah@nneu.com.

Updated: 1 April 2024