I. Introduction  /  II. Overview  /  III. Data collections and uses  /  IV. Choice and transparency  /  V. Updates to this notice

I. Introduction

When you use 360Hubspot, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

Last modified: March 10, 2020

Effective date: April 6, 2020

II. Overview

  1. Scope

This notice applies to users of 360Hubspot’s services anywhere within Nigeria and Africa at large and the countries in which we operate, including users of 360Hubspot’s apps, websites, features, or other services.

This notice describes how 360Hubspot and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services within Nigeria and Africa and locations where our app is used unless covered by a separate privacy notice. This notice specifically applies to:

  • Customers: individuals who request and purchase adverts products and services.
  • Media Owners: individuals who provide, or submit their advert rates of products (billboards, lamp poles, OOH and all other inventories)  to 360Hubspot, individually or through partner companies.
  • Television Stations: individuals who provide, or submit their advert rates of products and services to 360Hubspot.
  • Radio Stations: individuals who provide, or submit their advert rates of products and services to 360Hubspot.
  • Newspaper Publications: individuals who provide, or submit their advert rates of products and services to 360Hubspot.
  • BRT: Government body that provides, or submits advert rates of to 360Hubspot.

This notice also governs 360Hubspot’s other collections of personal data in connection with 360Hubspot’s services. For example, we may collect the contact information of individuals who use accounts owned by 360Hubspot for Business customers or of owners or employees of 360Hubspot partners, or we may collect other personal data in connection with our technology and features.

All those subject to this notice are referred to as “users” in this notice.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us through the addresses below with any questions regarding our practices in a particular country or region.

 

B. Data controller and transfer

360Hubspot is the data controller for the personal data collected in connection with the use of 360Hubspot’s services anywhere else.

360Hubspot (350-360 Maryland-Ikorodu road, Lagos. Nigeria) is the data controller for the personal data collected in connection with the use of 360Hubspot’s services in Nigeria and anywhere our services are used.

III. Data collections and uses

A. The data we collect

360Hubspot collects:

  • Data provided by users to 360Hubspot, such as during account creation
  • Data created during use of our services, such as location, app usage, and device data
  • Data from other sources, such as 360Hubspot partners and third parties that use 360Hubspot APIs or vice-versa

The following data is collected by or on behalf of 360Hubspot:

  1. Data provided by users. This includes:
  • User profile: We collect data when users create or update their 360Hubspot accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes company documents relating to advertising or media ownership, membership or insurance information of the above, user settings. For more information, please see the section titled “How we use personal data.”
  • Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
  • User content: We collect the information users submit when they contact 360Hubspot customer support, provide ratings or compliments for other users or ooh partners, radio, tv, digital or otherwise contact 360Hubspot. This may include feedback, photographs or other recordings collected by users.
  1. Data created during use of our services. This includes:
  • Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, date and time the service was provided, amount charged, and payment method.
  • Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
  •  Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
  1. Data from other sources. This includes:
  • User feedback, such as ratings, feedback, or compliments.
  • Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
  • 360Hubspot account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of 360Hubspot for Business accounts.
  • 360Hubspot business partners through which users create or access their 360Hubspot account, such as payment providers, social media services, or apps or websites that use 360Hubspot’s APIs or whose APIs 360Hubspot uses.
  • Publicly available sources.
  • Marketing service providers.

360Hubspot may combine the data collected from these sources with other data in its possession.

B. How we use personal data

360Hubspot collects and uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use the data we collect:

  • To enhance the safety and security of our users and services
  • For customer support
  • For research and development
  • To enable communications between users
  • To send marketing and non-marketing communications to users
  • In connection with legal proceedings

360Hubspot does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

360Hubspot uses the data it collects for purposes including:

  1. Providing services and features. 360Hubspot uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

  • Create and update users’ accounts.
  • Verify advert rates, background history, and eligibility of rates .
  • Offer, process, or facilitate payments for our services.
  • Track and share the progress of deliverables.
  • Enable features that allow users to provide feedback, referrals to 360Hubspot.
  • Enable features to personalize users’ 360Hubspot accounts, such as creating bookmarks for favorite places and to enable quick access to previous destinations. We may, for example, present 360Hubspot Help users with personalization.
  • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
  1. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:
  • Screening advert rates submitted, physical products and services before enabling their use of our services and at subsequent intervals, including thorough reviews of background checks, where permitted by law, to help prevent the use of our services by illegal individuals.
  • Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
  • Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating media owners with low ratings or who otherwise violated such guidelines across countries of operations.
  1. Customer support. 360Hubspot uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:
  • Direct questions to the appropriate customer support person
  • Investigate and address user concerns
  • Monitor and improve our customer support responses and processes
  1. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.
  2. Marketing. 360Hubspot may use the data we collect to market our services to our users. This includes sending user’s communications about 360Hubspot services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by 360Hubspot partners. For example, if a user has placed 360Hubspot Help order, we may provide recommendations, promotions, or ads about similar advert products and or services offered by other 360Hubspot partners. Although we may send users communications about 360Hubspot partners’ products and services, we do not sell users’ personal data to or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of 360Hubspot’s services, and user preferences and settings.

  1. Non-marketing communications. 360Hubspot may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of 360Hubspot or its partners.
  2. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to the use of 360Hubspot’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
  3. Automated decision-making

We use personal data to make automated decisions relating to the use of our services. This includes:

  • Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm 360Hubspot, its users, and others. In some cases, such as when a user is determined to be abusing 360Hubspot’s referral program, such behavior may result in automatic deactivation.

C. Cookies and third-party technologies

360Hubspot and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. 360Hubspot uses cookies and similar technologies for purposes such as:

  • Authenticating users
  • Remembering user preferences and settings
  • Determining the popularity of content
  • Delivering and measuring the effectiveness of advertising campaigns
  • Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

 

D. Data sharing and disclosure

Some of 360Hubspot’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

360Hubspot may share the data we collect:

  1. With other users

This includes sharing:

  • Users’ first name, rating, advert location pickup and/or dropoff locations for physical ads, radio interviews, etc.

 

  • Delivery recipients’ first name, delivery address, and order information with their delivery partner. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant partner and delivery partner.
  • ·                     For those who participate in 360Hubspot’s referral program, we share certain personal data of referred users, with the user who referred them, to the extent relevant to determining the referral bonus.
  1. At the user’s request

This includes sharing data with:

  • Other people at the user’s request. For example, we share a product ETA and location with a friend when requested by that user, or a user’s advert trip information.
  • 360Hubspot business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, 360Hubspot may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; those with an API or service with which we integrate; or other 360Hubspot business partners and their users in connection with promotions, contests, or specialized services.
  1. With the general public

Questions or comments from users submitted through public forums such as 360Hubspot blogs and 360Hubspot social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

  1. With the 360Hubspot account owner

If a user requests or places an order using an account owned by another party, we may share their order or information, including real-time location data, with the owner of that account. This occurs, for example, when:

  1. Requests are made from 360Hubspot subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

  1. With 360Hubspot service providers and business partners

360Hubspot provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

  • Payment processors and facilitators
  • Background check and identity verification providers (drivers and delivery partners only)
  • Cloud storage providers
  • Marketing partners and marketing platform providers, including social media advertising services
  • Data analytics providers
  • Research partners, including those performing surveys or research projects in partnership with 360Hubspot or on 360Hubspot’s behalf
  • Vendors that assist 360Hubspot to enhance the safety and security of its apps
  • Consultants, lawyers, accountants, and other professional service providers
  • Fleet partners
  • Insurance and financing partners
  • Airports
  • Lime and other local providers
  • Restaurant partners and/or their point of sale providers
  • Vehicle solution vendors or third-party vehicle suppliers
  1. For legal reasons or in the event of a dispute

360Hubspot may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect 360Hubspot’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

 

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

  1. With consent

360Hubspot may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

 

E. Data retention and deletion

360Hubspot retains user profile, transaction, and other personal data for as long as a user maintains their 360Hubspot account.

360Hubspot may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

360Hubspot retains user profile, transaction, and other information for as long as a user maintains their 360Hubspot account. Users may request the deletion of their account at any time through the Settings > Privacy menus in the 360Hubspot app. Following such requests, 360Hubspot deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, 360Hubspot retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, 360Hubspot may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, 360Hubspot will delete the account as described above.

360Hubspot may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if 360Hubspot deactivates a user’s account because of unsafe behavior or security incidents, 360Hubspot may retain certain information about that account to prevent that user from opening a new 360Hubspot account in the future.

F. Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of 360Hubspot’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

  1. To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

  • User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their, orders, and accounts; and enable users to make payments or receive earnings.
  • Usage data, which is necessary to maintain, optimize, and enhance 360Hubspot’s services, including to determine incentives, connect users and media owners, and calculate costs and earnings.
  • Transaction information
  • Information relating to customer support.
  1. For purposes of the legitimate interests of 360Hubspot or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent the use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of 360Hubspot’s apps.

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing 360Hubspot’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

  1. To fulfill 360Hubspot’s legal obligations

For example, 360Hubspot is subject to laws and regulations in Nigeria and Africa at large that require it to collect and retain data about our users, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

360Hubspot may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.

  1. With consent

360Hubspot may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

IV. Choice and transparency

360Hubspot enables users to access and control the data that 360Hubspot collects, including through:

  • In-app settings
  • Device permissions
  • In-app rating pages
  • Marketing opt-outs

360Hubspot also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that 360Hubspot restrict its processing of user personal data.

  1. Privacy settings

Settings menus in the 360Hubspot app for users give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from 360Hubspot. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

  • Location data

Location data helps improve our services, navigation, and customer support.

Users may enable or disallow 360Hubspot to collect location data from their mobile devices through the Settings > Privacy menus in the 360Hubspot app. Users and delivery recipients can enable or disallow such collections through the settings on their mobile devices.

  • Notifications: account updates

360Hubspot provides users with updates related to activity on their accounts. These notifications are a necessary part of using the 360Hubspot app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menus in the 360Hubspot app.

  • Notifications: discounts and news

Users may enable 360Hubspot to send push notifications about discounts and news from 360Hubspot. Push notifications may be enabled or disabled through the Settings > Privacy menus in the 360Hubspot app.

  1. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the 360Hubspot app requests permission to access certain types of data and give users the option to grant or refuse permission. Android devices notify users of the permissions that the 360Hubspot app seeks before their first use of the app, and the use of the app constitutes a grant of such permission.

  1. Rating look-up

After every sale, clients are able to rate the service of the media owners on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, media owner’s ratings are available to their customers.

 

  1. Marketing opt-outs

Users may opt-out of receiving promotional emails from 360Hubspot. Users may also opt-out of receiving emails and other messages from 360Hubspot by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their accounts.

  1. User data requests

360Hubspot provides users with a variety of ways to learn about, control, and submit questions and comments about 360Hubspot’s handling of their data. Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.

  • Receiving data: Users can ask for a copy of data that 360Hubspot collects from them with their consent or as necessary to provide our services.
  • Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in 360Hubspot’s apps. They may also ask that 360Hubspot change or update their data, including if they believe such data is inaccurate or incomplete.
  • Deleting data: Users may request the deletion of their account at any time through the Settings > Privacy menus in the 360Hubspot app, or through 360Hubspot’s website.
  • Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. 360Hubspot may continue to process data after such objection or request to the extent required or permitted by law.

In addition, depending on their location, users may have the right to file a complaint relating to 360Hubspot’s handling of their personal data with the data protection authority in their country.

 

  1. Updates to this notice

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the 360Hubspot apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, the use of our services by users will be understood as consent to the updates to the extent permitted by law.