Policy on Personal Data Processing
1. General Provisions
This personal data processing policy is formulated in accordance with the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” and outlines the procedure and measures for ensuring the security of personal data implemented by https://vod.com.ng (hereinafter referred to as the Operator).
1.1. The Operator prioritizes the protection of human and citizen rights and freedoms in processing personal data, ensuring the safeguarding of privacy, personal, and family secrets.
1.2. This policy regarding the processing of personal data (the “Policy”) applies to all information the Operator may obtain about visitors to the website https://vod.com.ng.
2. Key Concepts Used in the Policy vod.com.ng
2.1. Automated processing of personal data means the processing of personal data using computer technology;
2.2. Blocking of personal data refers to the temporary cessation of personal data processing (except when processing is necessary to clarify personal data);
2.3. Website – a collection of graphic and informational materials, along with software and databases, accessible on the Internet at https://vod.com.ng;
2.4. Information system of personal data – a collection of personal data in databases and information technologies and technical tools that ensure its processing;
2.5. De-identification of personal data involves actions that make it impossible to determine the ownership of personal data without additional information;
2.6. Processing of personal data includes any action (operation) or set of actions performed with or without automation tools, such as collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, and destruction of personal data;
2.7. Operator – a state body, municipal authority, legal entity, or individual that organizes and/or carries out the processing of personal data, determining the purposes and composition of personal data to be processed, and the actions performed with personal data;
2.8. Personal Data – any information related directly or indirectly to a specific or identifiable user of the website https://vod.com.ng;
2.9. User – any visitor to the website https://vod.com.ng;
2.10. Provision of personal data involves actions aimed at disclosing personal data to a specific person or group of persons;
2.11. Dissemination of personal data involves actions aimed at disclosing personal data to an indefinite number of persons or making personal data publicly accessible;
2.12. Cross-border transfer of personal data involves the transfer of personal data to a foreign country, authority, individual, or legal entity;
2.13. Destruction of personal data involves actions resulting in the irretrievable destruction of personal data, making it impossible to restore the personal data in the information system.
3. The Operator May Process the Following Personal Data of the User
3.1. Email address;
3.2. The site also collects and processes impersonal visitor data (including cookies) using Internet statistical services (Yandex Metrika, Google Analytics, and others).
3.3. The aforementioned data are collectively referred to as Personal Data in this Policy.
4. Purposes of Personal Data Processing
4.1. The purpose of processing the User’s personal data is to inform the User via emails.
4.2. The Operator may also send notifications about new products, services, special offers, and events. Users can opt-out of receiving such notifications by emailing the Operator at vod.com.ng@gmail.com with the subject “Unsubscribe from notifications about new products, services, and special offers”.
4.3. Anonymized user data collected via Internet statistical services are used to gather information on user activities on the website, improving the website quality and content.
5. Legal Basis of Personal Data Processing
5.1. The Operator processes the User’s personal data only if the User submits it via forms on the website https://vod.com.ng. By submitting their personal data, the User consents to this Policy.
5.2. The Operator processes impersonalized data if allowed in the User’s browser settings (e.g., cookie storage and JavaScript usage).
6. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
The Operator ensures the security of personal data by implementing necessary legal, organizational, and technical measures to comply fully with applicable personal data protection laws.
6.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access.
6.2. The User’s personal data will not be disclosed to third parties, except as required by law.
6.3. If inaccuracies in personal data are identified, the User can update them by emailing the Operator at vod.com.ng@gmail.com with the subject “Personal data update”.
6.4. The period of personal data processing is unlimited. The User may withdraw their consent to personal data processing at any time by emailing the Operator at vod.com.ng@gmail.com with the subject “Withdrawal of consent to personal data processing”.
7. Cross-border Transfer of Personal Data
7.1. Before cross-border transferring personal data, the Operator ensures that the foreign country provides adequate protection for the rights of personal data subjects.
7.2. Cross-border transfer to countries that do not meet these requirements is allowed only with the personal data subject’s written consent and/or agreement fulfillment.
8. Final Provisions
8.1. Users can seek clarification on personal data processing by contacting the Operator at vod.com.ng@gmail.com.
8.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
