This policy is effective as from 30 September 2021
- Personal Data
- How We Share Your Personal Data
- Tracking Tools, Advertising and Opt-Out
- Data Security and Retention
- Personal Data of Children
- Contact Information
Personal Data that we collect.
Profile or Contact Data
Examples of Personal Data We Collect
First and last name
Type of device/operating system/browser used to access the Services
Web page interactions
Referring webpage/source through which you accessed the Services
Statistics associated with the interaction between device or browser and the Services
Information from your social media profiles, if provided
Professional or Employment-Related Data
Business information provided through ad placements or other interactions
We collect Personal Data about you from the following categories of sources:
When you provide such information directly to us.
When you create an account or use our interactive tools and Services.
When you voluntarily provide information in free-form text boxes through the Services or through responses to polls, surveys or questionnaires.
When you use the Services and such information is collected automatically.
Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
If you use a location-enabled browser, we may receive information about your location.
If you download and install certain applications and software we make available such as our Mibachat app, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Categories of Third Parties with Whom We Share this Personal Data:
We may use analytics providers to analyse how you interact and engage with the Services, or third parties may help us provide you with customer support.
We may use vendors to obtain information to generate leads and create user profiles.
We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
Creating and managing your account or other user profiles.
Providing you with the products, services or information you request (including processing orders and billing, if applicable).
Meeting or fulfilling the reason you provided the information to us.
Providing support and assistance for the Services.
Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Doing fraud protection, security and debugging.
Marketing the Services
Marketing and selling the Services.
Showing you advertisements, including interest-based or online behavioural advertising.
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Mibagu or the Services.
Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
Protecting the rights, property or safety of you, Mibagu or another party.
Enforcing any agreements with you.
Responding to claims that any posting or other content violates third-party rights.
We will not collect additional categories of Personal Data (such as audio or video uploads) or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on country laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, technology and communication providers.
Security and fraud prevention consultants.
Support and customer service vendors.
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
Companies that track how users found or were referred to the Services.
Companies that track how users interact with the Services.
Business Partners. These parties partner with us in offering various services. They include:
Businesses that you have a relationship with.
Companies that we partner with to offer joint promotional offers or opportunities.
Parties You Authorize, Access or Authenticate
Third parties you access through the services.
Social media services.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyse, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools, Advertising and Opt-Out
We use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Information about Interest-Based Advertisements:
We display advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviours (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data.
The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected about you but this is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Data Sales Opt-Out and Opt-In
We sell your Personal Data, subject to your right to opt-out of these sales.
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section.
We may sell your Personal Data to the following categories of third parties:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell the Personal Data of minors under 18 years of age.
We Will Not Discriminate Against You for Exercising Your Rights to your privacy.
We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you request that we do not share your information.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Personal Data processed for contractual necessity
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
Personal Data processed for legitimate interest
We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include:
Providing, customizing and improving the Services.
Marketing the Services.
Corresponding with you.
Meeting legal requirements and enforcing legal terms.
Completing corporate transactions.
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain amount of your Personal Data by logging on to your account.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Transfers of Personal Data
The Services are hosted and operated in Namibia through Mibagu and its service providers, and if you do not reside in Namibia the laws may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Mibagu in Namibia and will be hosted on Namibian servers, and you authorize Mibagu to transfer, store and process your information to and in Namibia, and possibly other countries. You hereby consent to the transfer of your data to Namibia. In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.