This policy refers to a set of web products and mobile apps: Company Panel, Webdesk, Dispatch Panel, mobile booking apps for iOS and Android platforms, mobile driver apps for iOS and Android platforms (Service), released as a part of Shilu ANA.
Shilu ANA is a product of Junubia Host Co.LTD is a company registered in South Sudan, Juba with registration address Juba, Malakia, City Mall Building, first floor. Shilua ANA is committed to protecting and respecting the user’s privacy.
By using Shilu ANA’ services or registering, downloading information or entering the Site, the Apps, Dispatch Panel and/or Company panel you consent to the processing (collecting, using, disclosing, retaining or disposing of personal data) of your information under the terms of this policy.
1. INFORMATION SHILU ANA MAY COLLECT FROM YOU
Shilu ANA may collect and process data about you relating to:
- the provision of services or online content in order to deal with your requests and enquiries. This includes data provided at the time of subscribing to any services or news Shilu ANA offers, downloading data posted on the Site, the Apps, Dispatch Panel and/or Company panel, posting material or requesting further services;
- data in connection with or participation in any promotions or competitions sponsored, promoted or offered by us and/or any third party and any data provided to us by way of feedback, profile forms or site issues;
- your contacting us, for example by email, post or telephone, in which case SHilu ANA may keep a record of that correspondence in our customer relationship management system Base to respond to your enquiries and improve its services. Thereafter, SHilu ANA may use your email address to contact you about its services;
- other information from your interaction with the Site, the Apps, Dispatch Panel and/or Company panel, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the Site, ad data, IP address, standard web log information and the resources that you access, when it is required for SHilu ANA own purposes.
2. THIRD PARTY ANALYTICS SOFTWARE
This Site, Dispatch Panel, Company Panel use Google
Analytics, a web analytics service provided by Google, Inc. (“Google”)
and Yandex Metrica, a web analytics service provided by Yandex, Ltd.
(“Yandex”). These services help us to improve your experience of
are stored on your computer/device and contain information about your
visit: duration, visited pages, country, browser type, device type, etc.
To learn more about Google Analytics, including how to opt out of it,
visit https://www.google.com/analytics/ and https://tools.google.com/dlpage/gaoptout.
Yandex Metrica helps us to get statistical data about visitors’ behaviour on our Site. Yandex Metrica may record mouse clicks, mouse movements, scrolling activity, etc. By analysing this statistical data, we are able to improve the navigation and design of the site to provide our users with better experience and ability to find and use the information of our Site faster and more efficiently. To learn more about Yandex Metrica, visit https://metrica.yandex.com/about.
3. FACEBOOK PIXEL, ADROLL PIXEL AND GOOGLE ADS
We use advertising functionality of Facebook (pixel) and
AdRoll (pixel) that are added to our Site’s pages and allow us to send
them the data about visitors’ actions performed on our Site. By means of
pixels, Facebook creates custom audiences of people who visit specific
pages or set of pages and/or make a conversion. We do not transfer or
disclose any personally identifiable information to Facebook.
By means of Google Analytics, we use features like:
– Remarketing with Google Analytics;
– Google Display Network Impression Reporting;
– Google Analytics Demographics and Interest Reporting;
– Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers. We do not transfer or disclose any personally identifiable information to Google. You may adjust the settings of the ads you want or do not want to see here: https://www.google.com/settings/u/0/ads/authenticated.
By means of Google Maps Controller/APIs we collect data used for geocoding and autocomplete that is used within our Applications. Use of the controller is covered by Google Maps Controller Data Protection Terms that can be seen here: https://privacy.google.com/businesses/mapscontrollerterms/
4. IP ADDRESSES AND COOKIES
Shilu ANA may collect information about your computer and/or your mobile telephone device, including where available your IP address, operating system and browser type. We do it for system administration and to improve user browsing experience. These statistics are gathered anonymously and do not identify any individual.
For the same reason, Shilu ANA may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer and/or your mobile telephone device. Cookies contain information that is transferred to your computer’s and/or mobile telephone device’s hard drive. They help us to improve the Site and to deliver a better and more personalised service. They enable us:
- to estimate Shilu ANA audience size and usage pattern;
- to store information about your preferences and so allow us to customise the Site according to your individual interests;
- to continually improve SHilu ANA services;
- to recognise you when you return to the Site.
5. WHERE SHilu ANA STORES YOUR PERSONAL DATA
Where SHilu ANA has given you (or where you have chosen) a username, login or password which enables you to access certain parts of the Site, the Apps, Dispatch Panel and/or Company panel, you are responsible for keeping this information confidential. Shilu ANA asks you not to share a username, login or password with anyone.
Shilu ANA restricts access to your data to individuals who need access to it in order to process it on SHilu ANA behalf. The employees who work with your data are bound by confidentiality agreements. In case they will fail to meet the required security of the data processing, Shilu ANA will sue them.
6. WHY DO WE COLLECT, STORE AND PROCESS YOUR DATA
SHilu ANA uses information held about you in the following ways:
- to ensure that content on the Site and/or the App is presented in the most effective manner for you and for your computer and/or your mobile telephone;
- to provide you with information, products or services that you request from Shilu ANA or which may interest you, where you have consented to be contacted for such purposes;
- to carry out SHilu ANA obligations arising from any contracts entered into between you and SHilu ANA (including but not limited to pick-up and drop-off destinations);
- to verify your identity when you sign in to any of our Site or App;
- to allow you to participate in interactive features of Shilu ANA service, when you choose to do so;
- to contact you for your views on Shilu ANA services and to notify you about changes or developments to SHilu ANA service;
- to update you with operational news and information about our Site and App;
- to improve the Site, the Apps, Dispatch Panel and/or Company panel including tailoring it to your needs;
- to identify potential fraudulent activity and to ensure compliance with the user terms that apply to Sites;
- to use GPS to identify the location of users;
- to respond to support tickets, and help facilitating the resolution of any disputes;
Shilu ANA may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and SHilu ANA or they may contact you about these by email, post or telephone.
If you are a new customer, and if SHilu ANA permits selected third parties to use your data, SHilu ANA (or any third party) will contact you by electronic means only, and only if you have consented to this. By using the Site and/or the App you give your consent for us to provide your data to third parties and for the data you provide Shilu ANA to be used for additional reasons other than those set out above. You also consent to be contacted for marketing purposes.
If you do not want SHilu ANA to use your data in these ways, or to pass your details on to third parties for marketing purposes, please contact Shilu ANA by email at email@example.com. You can also unsubscribe from any newsletter, anytime.
7. HOW LONG DO WE KEEP YOUR DATA?
We will retain personal information, customer and business information for as long as it is needed to:
- Provide products, services and information that you or your organization have requested.
- To communicate with you about a request you have submitted to us.
8. DISCLOSURE OF YOUR INFORMATION
1. Third Parties: Under contract, we may disclose your information to third parties. They help us providing you and others our Services (such as, but not limited to, fraud/spam investigations, payment processing, site analytics and operations). If we disclose any information to third parties, we either do it on a non-identifiable basis, or we use a unique identifier. Such identifier cannot be tracked back to you. Third parties are obliged to secure the data they receive from Shilu ANA.
2. Business: SHilu ANA may also pass your information on to any successor or potential successor in title to the business and suppliers that process data on SHilu ANA behalf both in South Sudan and abroad. SHilu ANA may also use and disclose information in aggregate (so that no individual customers are identified) for marketing and strategic purposes.
3. Advertising Partners: To enable the advertisements of our service, we may share a unique advertising identifier with our third-party advertising partners and advertising service providers. Such identifier is not attributable to you. We may also share technical data about you (your language preference, country, city, and device data), based on our legitimate interest, with our advertising partners. This includes partners managing our advertising placements and also advertisers themselves and their agencies or third parties managing their advertising demands.
9. MARKETING COMMUNICATION
When you get our product, you may occasionally receive
promotional emails. We are considering your interests in the specific
products. This is why in most cases our emails contain relevant
information about special offers, news, and new product features. We
send this information by direct emails ourselves, or via third-party
email service providers such as Sendgrid and Drip.
At any time, you may stop receiving marketing and promotional information by clicking “Unsubscribe” at the bottom of each email. You can send us a direct request to unsubscribe you from further promotional emails as well.
In case you unsubscribe from receiving our promotional emails, you may miss news about product updates. However, you will still be able to visit our blog and search for the news you want to read.
10. YOUR RIGHTS
You have the right to request Shilu ANA to not process your personal data for marketing purposes. To exercise this right, contact SHilu ANA directly by visting our office at Juba, City mall Building, First Floor or by email at firstname.lastname@example.org.You also have the right to ask Shilu ANA to amend any data it holds about you if it is inaccurate or misleading as to any matter of fact. Shilu ANA also asks you to provide it with two forms of photographic identification so that SHilu ANA can verify your identity. Any request to amend SHilu ANA records should be submitted in writing and addressed to Shilu ANA at main office, Juba, City mall Building, First Floor or by email at email@example.com.
11. ACCESS TO INFORMATION
The General Data Protection Regulation 2016/679/EU
(GDPR) gives you the right to access your personal information, rectify
the information we hold about you, erase your personal information,
restrict our use of your personal information, object to our use of your
personal information, receive your personal information in a usable
electronic format and transmit it to a third party (right to data
portability), lodge a complaint with your local data protection
authority. If you would like know more details about these rights or to
exercise them, please contact us at the given address listed below. We
will contact you if we need additional information from you in order to
honor your requests.
We must have a legal basis to process your personal information. In most cases the legal basis is one of the following:
- to fulfill our contractual obligations to you, for example to provide the services, to ensure that invoices are paid correctly.
- where you have given your consent to the processing.
- to comply with our legal obligations, as explained above.
- to meet our legitimate interests, for example to understand how you use our products and services and to enable us to derive knowledge from that, which allows us to develop new products and services, and to personalize the service for you and the ads you see. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
- to protect the vital interests of the data subject or of another natural person.
necessary for the performance of a task carried out in the public interest.