1. PRIVACY POLICY

Welcome to Zoto™ website, applications, products and services offered by Hedonmark Management Services Limited (HMSL) including its affiliates and subsidiaries having its registered office at Plot 52 Ahmadu Bello Way, Victoria Island, Lagos, Nigeria , through its website and mobile network (collectively, including all Materials available through the www.zoto.com.ng or www.zoto.ng domain names and the Zoto™ website network, including mobile sites and apps, “Sites”). This End User License Agreement (“EULA”) describes the terms and conditions applicable to your access and use of the Sites and the products and services offered therein.

This EULA applies to all visitors, users, and others who access the Services (“users”/ “you”). By accessing the Services, you agree to be bound by the terms and conditions of this Policy.

This Policy explains:

By using these sites/application and the services and products offered on or through them, you may access the Zoto™ Website and the Zoto™ recharge and payment service. As used in this EULA, the term, “Software” includes the Zoto™ Website, Mobile Application or any other software owned or controlled by HMSL which you have selected for downloading and installation, and any online or enclosed documentation, data distributed to your computer for processing and any future programming fixes, updates and upgrades provided to you. Software includes analytics and customer service components and its use to occur only as permitted by usage rules set by HMSL and/or its licensors who have provided Materials (as defined herein below) for the Services

Zoto’s Confidentiality Obligation

We fully value your privacy and shall undertake all that is necessary to ensure that any information obtained from you will not be misused in any manner. Except as otherwise provided in this Policy or otherwise required under applicable law, we shall not disclose any information obtained from you to any third party, without your express consent.

We have stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.

Zoto™ will not sell, share or rent your personal information to any 3rd party or use your email address/mobile number for unsolicited emails and/or SMS. Any emails and/or SMS sent by Zoto™ application will only be in connection with the provision of agreed services & products and this Privacy Policy. Periodically, we may reveal general statistical information about Zoto™ & its users, such as number of visitors, number and type of goods and services purchased, etc. We reserve the right to communicate your personal information to any third party that makes a legally-compliant request for its disclosure. We reserve the right to use your Personal Information for our Service offers, promotions etc.

COLLECTION OF INFORMATION

Personal Information refers to and includes all information that can be linked to a specific individual or to identify any individual, such as name, address, mailing address, telephone number, email ID, credit card number, cardholder name, card expiration date, information about your mobile phone, that may have been voluntarily provided by the user in connection with availing any of the services on Zoto™.

User agrees and voluntarily authorizes Zoto™ to collect his/her personal information as well as information regarding the domain and host from which user accesses the internet, the Internet Protocol [IP] address of the computer or Internet service provider [ISP] you are using, and anonymous site statistical data.

The information, including Personal Information provided by you will be used and analyzed by us for the following purposes:

  1. Optimization of the Services provided to you and creation, development, operation, delivery, and improvement our products and content.
  2. Provision of support in relation to the Services and redressing complaints or grievances that you may have.
  3. Handling of break-downs and malfunctions.
  4. Building of anonymised and aggregate summaries of user information, which do not disclose any of your Personal Information.
  5. Keeping you posted on our latest product announcements, software updates, and upcoming events.
  6. Prevention of loss, fraud and other illegal activities.
  7. Sending important notices, such as communications about purchases and changes to our terms, conditions, and policies.

COOKIES

A "cookie" is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Zoto™ uses cookie and tracking technology depending on the features offered. No personal information will be collected via cookies and other tracking technology; however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

USE AND DISCLOSURE OF YOUR INFORMATION

We may, as part of our services and operation of the Services, disclose information, including Personal Information received from you to third parties. We may also share Personal Information with third parties to help detect and/ or prevent identity theft, fraud and other potentially illegal acts, or to prevent abuse of Services provided to you.

We may be required to share information, including Personal Information received from you with Government agencies and/ or to any third party by an order under applicable law.

Further, we may share your information, including Personal Information with group or affiliate entities (“Affiliates”), who may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences).

We may also share certain aggregated non-identifiable information with third-party advertising partners. This information would allow third-party advertising networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

We may remove parts of information that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information with third parties, including our enterprise customers as part of our services. However, we wish to clarify that such aggregated information, which includes data collected from users including yourself, will not include any individually identifiable or personal information relating to you. Any such disclosure of individually identifiable or personal information shall only be disclosed with your prior and express consent.

As previously explained, all such disclosures shall be strictly made as per the terms of this Policy and the terms of applicable law, including, without limitation, the Privacy Rules. We shall maintain stringent confidentiality measures and adequate security standards while making such disclosures, and shall ensure that all third parties to whom disclosures are made are bound by equivalent confidentiality obligations.

The Services provided by us may enable you to communicate with other users or to share information with such other users. We hereby expressly disclaim any liability for any misuse of such information that is made available by you in such a manner to other users or other third parties.

OPT-OUT

Since you have read and understood the terms of this Policy, you would now be well aware of the Zoto’s confidentiality obligations and its use of information collected from you. In the event you are not agreeable to the terms and conditions under this Privacy Policy and you are presently availing any Services, we request you to kindly withdraw your consent and uninstall any mobile or other application of Zoto through which you may be availing Services.

All information, including Personal Information provided by you is voluntary. You may, at any time withdraw your consent, in accordance with these terms. However, in the event you withdraw consent to provide information, including Personal Information, you agree that you will no longer be permitted to use our Services. To clarify, in the event the relevant information that you wish to withdraw consent for, is basic information required to be provided for availing of Services, for example, installation of the mobile application, in such case the entire Service would be discontinued and you will be required to uninstall all mobile application(s) connected with the Service.

You can access, modify, correct and eliminate information provided by you which has been collected pursuant to your decision to become a user of Services.