INTRODUCTION
Awarri Technologies Limited (collectively referred to as “Awarri”, “we”, “us” or “our” in this Privacy Policy) is enabling the development and adoption of frontier technology on the African continent by leveraging on Artificial Intelligence to build lasting technological solutions. Awarri respects your privacy and is committed to protecting your Personal Data. This Privacy Policy will inform you as to how we will utilize and look after your Personal Data when you provide it to us for use in our Large Language Model project (the “Project”) including your privacy rights and how the law protects you.
SCOPE AND CONSENT
By clicking the consent button on our website or signing a physical copy of this Privacy Policy, you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described herein (including to contact you), and for all other purposes permitted under applicable personal information privacy statutes, anti-spam legislation, and consumer protection laws.
For the avoidance of any doubt, this Privacy Policy it to be reviewed under the Nigeria Data Protection Act (NDPA) and the applicable data protection regulations in force in Nigeria.
IMPORTANT INFORMATION AND WHO WE ARE
3.1 Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how Awarri collects and processes your Personal Data through its use in the Project.
3.2 Data Controller
Awarri is the data controller and is responsible for your Personal Data However, it is also possible for Awarri to act as data processor, depending on specific contractual obligations that are made known to you.
3.3 Changes to the Privacy Policy and Your Duty to Inform us of Changes
We keep our Privacy Policy under regular review. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes at any time.
3.4 Third-Party Links
The present document may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website, plug-in or application you visit.
THE DATA WE COLLECT ABOUT YOU
4.1 Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
4.2 We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
4.2.1 Identity Data
This includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
4.2.2 Contact Data
This includes home address, email address and telephone numbers.
4.2.3 Speech Data
This is spoken content that contains your personal information.
4.2.4 Technical Data
This includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or application.
4.2.5 Profile Data
This includes your username and password, history of transactions entered into by you, feedback and survey responses.
4.2.6 Usage/Behavioural Data
This includes information about how you use our applications and services.
4.2.7 Marketing and Communications Data
This includes your preferences in receiving marketing from us and our third parties and your communication preferences.
4.3 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 in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing our website or application. 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 Privacy Policy.
4.4 We may collect Sensitive Personal Data about you. This could include details about your race or ethnicity, religious or philosophical beliefs. Please note that we handle all sensitive Personal Data in accordance with applicable laws and regulations.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
5.1 Direct User Contributions
When you interact with our platform, we collect the data you provide. This could be text you type, voice recordings you make, or voice commands you use. We use this information as training sources for the Project.
5.2 Surveys and Questionnaires
From time to time, we may ask for your feedback on the Project’s performance. This is always voluntary. If you choose to provide feedback, we use your responses to improve the output of the Project.
5.3 Technical Data
As you interact with our applications and services, we will automatically collect Technical Data about your devices, browsing actions and patterns. We collect this Personal Data by using cookies, server logs, voice interaction, and other similar technologies. We may also receive Technical Data about you if you visit other websites and applications employing our cookies.
HOW WE USE YOUR PERSONAL DATA
6.1 We will only use your Personal Data when the law allows us to. Specifically, we will exclusively use your Personal Data for the following:
Training and improving the accuracy of the Project.
Enhancing user experience by personalizing interactions with the Project.
Conducting internal research and development to optimize the Project’s capabilities.
6.2 You have the right to withdraw your consent at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
7.1 We have set out below, in a table format, a description of the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
7.2 Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
Lawful basis for processing including basis of Legitimate Interest
Purpose/Activity: To train and improve the accuracy of the Project.
Type of Data
Identity
Contact and
Voice
Lawful basis for processing including basis of Legitimate Interest: Consent
Purpose/Activity: To enhance your experience by personalizing interactions with the Project.
Type of Data
Identity
Contact
Profile and
Voice
Lawful basis for processing including basis of Legitimate Interest: Consent
Purpose/Activity: To manage our relationship with you which will include:
Notifying you about changes to our terms or Privacy Policy
Asking you to leave a review or take a survey
Type of Data
Identity
Contact
Profile
Voice
Lawful basis for processing including basis of Legitimate Interest:
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how persons use our services)
INTERNATIONAL TRANSFERS
8.1 We do not transfer your Personal Data outside countries with limited data law security.
DATA SECURITY
9.1 We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, your personal data will be encrypted, we will ensure to limit access to your Personal Data to those employees directly concerned with the Project. We will ensure that we will carry out regular security audits and penetration testing on your personal data.
9.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Informing shall take place immediately without any undue delay, and in any case no later than 24 hours from the time on which it first became apparent that the breach had taken place.
9.3 If and where it is not possible to provide the information at the same time, it may be provided gradually without undue delay.
9.4 In any case, we shall cooperate with you or any other stakeholder and shall take all necessary actions, commercial and other, in accordance with the instructions of the competent authority, if any, for the purpose of investigating, limiting possible consequences and restoring to the fullest possible degree any Personal Data Breach.
. DATA RETENTION
10.1 How long will you use my Personal Data for?
10.1.1 We will only retain your Personal Data for as long as reasonably and obligatory necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
10.1.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory or other requirements.
10.1.3 In some circumstances you can ask us to delete your data (see below for further information).
10.1.4 In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
.1 Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to the following:
11.1.1 Request access to your Personal Data
This is commonly known as a “data subject access request”. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
11.1.2 Request correction of your Personal Data
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
11.1.3 Request erasure of your Personal Data
This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
11.1.4 Object to processing of your Personal Data
Object to processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
11.1.5 Right to withdraw consent
You may withdraw consent, if previously granted, at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
11.2 If you wish to exercise any of the rights set out above, please contact us.
. CONTACT
12.1 Please contact our Privacy Department with any questions or concerns regarding this Privacy Policy at [info@awarri.com]
12.2 If you have any questions or concerns regarding our policy, or if you believe our policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint through the email listed above, and we will respond to let you know when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.
