Draft for legal review
This is a plain language draft. A Nigerian lawyer has not reviewed it.
Legal
Privacy notice
How Spotledger collects and uses personal data, under the Nigeria Data Protection Act 2023. Plain words first, detail below.
01Who we are
Spotledger provides radio advert verification to companies in Nigeria. For the account details of your team, messages sent through this website and visits to it, Spotledger decides how personal data is used, so we are the controller.
For personal data inside the content you upload, the roles are set out in the data processing terms.
02What we collect
- Account details: name, work email, role and the company you belong to.
- Messages you send us, for example through the book a demo form: name, company, email, phone, role and your message.
- Your adverts, scripts and media plans, and the settings and actions in your workspace, which are written to an audit log.
- Recordings of public radio and transcripts of them. Presenters, callers and guests can be heard on radio, so recordings and transcripts can contain personal data.
- Basic technical data when you use the site, such as your browser and the pages you open. This website does not use advertising trackers.
03Why we use it, and on what basis
- To give you the service and keep your account safe: this is needed to perform our agreement with your company.
- To answer your messages and run a demo: this is our legitimate interest in replying to people who contact us.
- To improve matching and keep the service accurate, using reviewed decisions as training labels: this is our legitimate interest, limited to audio and transcripts of public radio.
- To meet legal duties, such as keeping records and notifying the regulator of a breach.
- We ask for your consent before sending marketing, and you can withdraw it at any time.
04Voices on the radio
Spotledger fingerprints adverts, not people. We do not use voices to identify individuals. Transcripts are used to find and check adverts and live reads, and to let customers search what was said on air.
06Sending data outside Nigeria
Some services we use run outside Nigeria, for example in South Africa, the UK or Europe. Where personal data leaves Nigeria, we follow the cross-border rules of the Nigeria Data Protection Act 2023 and record the basis for each transfer.
07How long we keep it
- Raw audio: 7 days.
- Clips around detections: about 13 months. Transcripts are kept no longer than the clips they relate to.
- Account details and your content: while your account is active, and deleted on request after you leave, unless the law requires us to keep something.
- Messages through the demo form: as long as needed to deal with your request, and then deleted.
08Your rights
Under the Nigeria Data Protection Act 2023 you can ask to see your personal data, correct it, have it deleted, restrict or object to its use, receive a copy you can move, and withdraw consent. You can also complain to the Nigeria Data Protection Commission.
You can reach us through the form on the book a demo page.
09Keeping it safe
Each organisation's data is kept separate, access is limited by role, secrets are never stored in code, and changes are logged.
If a personal data breach is likely to put people at risk, we will tell the Nigeria Data Protection Commission within 72 hours of becoming aware of it, and tell the people affected without delay.
10Children
Spotledger is for companies and is not aimed at children.
11Changes
If we change this notice in a way that matters, we will say so on this page and tell account owners.