1. Introduction

1.1School of Photography and Media Limited, a company registered in the Federal Republic of Nigeria, with a registered address at Victoria Island, Lagos State, Nigeria, owns and operates the website www.schoolofphotographyandmedia.com, schoolofphotographyandmedia.com and their subdomains (“Website”).
1.2This Privacy Policy (the “Policy”) forms a part of the Terms of Use relating to the use of the Website, and by using the Website you expressly consent to our collection, use and disclosure of your information in accordance with the terms of this Policy. We may amend this Policy at any time without notice, and such amendments become effective from the date upon which we make them available on the Website. If you do not agree to the Policy (including any amendments), then you should immediately cease using the Website.
1.3Throughout this Policy, the terms “we", "our", "us" means School of Photography and Media Limited and its subsidiaries, employees, officers, agents, affiliates or assigned parties.
1.4This Privacy Policy is effective between you and us as of the date you accept this Policy, and you do so by default through the use of the Website.
1.5If any term of this Policy is or may become for any reason invalid or unenforceable at law, the validity and enforceability of the remainder will not be affected.
1.6Data Controller means a person (either alone or jointly or in common with other persons) or legal entity, who, determines the purposes for which and the manner in which any personal data are, or are to be, processed.
1.7School of Photography and Media Limited is the Data Controller in respect of personal data processed by the Website. These group of companies shall be referred to in this Policy, collectively, as the “School of Photography and Media” or “SOPAM”, and, individually a “School of Photography and Media Company”.

2. YOUR INFORMATION

2.1The type of information we collect from you is either personal to you, or is general in nature:
  1. Personal Information: When you register on the Website as a user or otherwise, update your information, purchase any goods or services, take part in promotions or campaigns or contests, sign into our mobile application using Personal Information or a social media account, send emails to us, send support requests, contact estate agents via forms or phone numbers made available on our website, provide feedback, or when you report a problem with our website, you provide us with information that we store and process. Such information may include your name, address, phone number, email address, purchase and transaction history, billing information (including credit card information), interests, and other such 'Personal Information'.
  2. General Information: We also receive more general information from you as a result of your visits to, and use of, the Website. This general information does not identify you personally, and can include information such as your IP address, the date and time you access the Website, length of time you spend on the Website, your browsing history (recorded by the text and graphics files that compose that page), the Internet address of the website from which you linked directly to our Website, and other such 'General Information'.
  3. Payment Data: Payment Data is the information that you provide when you make online purchases. This may include your payment instrument number (e.g., credit card), your name and billing address, and the security code associated with your payment instrument (e.g., the CSV or CVV). You hereby acknowledge and agree that the Payment Data, to the extent consisting of details related to the manner and mode of payment of fees for the use of the Website and Services (such as details of your bank account, credit card, debit card, net banking, etc.), submitted by you while making payment of fees: (a) goes through the safe and secure transaction process provided by SOPAM’s payment gateway partners; (b) goes through the Visa or Mastercard pages, as the case may be, based on your payment method(s) in order to prevent any misuse of your payment details; and (c) that such payment details are not shared with the Website, SOPAM, its subsidiaries, affiliates and third parties or any other users of the Website and Services.
  4. Information We Receive from other Sources: We may receive information about you if you use any of the websites that we, or any SOPAM Company, operate, or from any other services that we provide. We are also working closely with third parties, including but not limited to, business partners, service providers, advertising networks, analytics providers, and search information providers. We may receive information about you from such third parties. This information may be combined with other information you provide to us, as described above.

3. COLLECTING AND USING INFORMATION

3.1Most of this Website can be used without giving us any information. However, certain services and third-party technology may involve collection and usage of information from you, including but not limited to, Google Analytics (a description of their specific data collection and processing practices can be found via the following link: https://www.google.com/policies/privacy/partners/).
3.2We use Personal Information to provide you with the following purposes:
  1. To provide any services that you request from us or another SOPAM Company;
  2. To provide a better service, and in particular to: keep internal records, as well as, improve our products, services and the Website;
  3. To communicate with you if you have ordered, purchased or participated in anything on the Website;
  4. To contact you for market research purposes;
  5. To provide you with information about new opportunities, promotions, special offers and other information that we may feel is relevant to you. If you contact us via the Website, or via email to the contacts set out on the Website, we may keep a record of that correspondence.
  6. To provide you, or permit other SOPAM Company, or selected third parties to provide you, with information about goods or services that may interest you;
  7. To customize or enhance your experience on our website and services, including via the display of adverts and direct communications you receive from us, which may be based on your activity on our website or the website of any other SOPAM Company;
  8. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website, or the website of another SOPAM Company or third parties’ website(s); and
  9. To make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them, which may be based on your activity on our website, or the website of another SOPAM Company or third parties’ website(s).
3.3We use General Information to help us make the Website more useful to customers (including to help us assess content of interest to visitors), and for other purposes such as determining the Website’s technical design specifications and identifying system performance or problem areas, for tracking activity on the Website, preparing reports, assessing trends, and otherwise monitoring the way in which the Website is being used none of which would be in a way that personally identifies any users.

4. DISCLOSURE OF PERSONAL INFORMATION

4.1We may share your Personal Information in connection with the purposes above with any SOPAM Company.
4.2You consent to us sharing your Personal Information with third parties in the following circumstances:
  1. selected real estate brokers, real estate brokerage firms, agents, developers or other service providers that we use, where asked to do so or it is an implicitly inherent part of your use of the Website. For example, when you enquire about a property of interest to you, we will pass your Personal Information to the estate agents handling that property sale or rental. Upon receipt of your Personal Information, the relevant third party is the Data Controller and their use of your information will be governed by their own terms of use and privacy policy; and
  2. business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  3. To our third-party service providers. We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfill the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfillment and delivery. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
4.3We may also share your Personal Information with third parties:
  1. in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets, along with its professional advisers. If SOPAM, a SOPAM Company or substantially all of its assets are acquired by a third party, Personal Information held by it about its customers will be one of the transferred assets;
  2. if required in order to obtain professional advice;
  3. if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or
  4. to protect the rights, property, or safety of SOPAM, each SOPAM Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection

5. SECURITY

5.1Keeping your Personal Information secure and preventing unauthorized access is of utmost priority to us, and we take all steps reasonably necessary to protect your Personal Information against any unauthorised access, use, alteration, disclosure or destruction. Whilst we have put in place physical, electronic and managerial procedures to secure and safeguard your Personal Information, we will not be held responsible for any unauthorised access by third parties and we cannot guarantee that the Personal Information provided by you or that is transmitted via this Website or by e-mail is totally secure and safe.

6. Storage of your personal information

6.1The information that we collect from you may be transferred to, and stored in a country outside the country in which the SOPAM Company is located, for who’s website you have accessed in order for the information to be collected. It may also be processed by staff operating outside such country, who work for us or for one of our suppliers. By submitting your information, you agree to this transfer, storage, and/or processing. We will take all steps reasonably necessary to ensure that your data is treated in accordance with this Policy.
6.2Where we have given you, or where you have created a password which is part of our services or allows you to access parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
6.3Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website. Any transmission of information made, is done so at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

7. Your right to access and correct your personal information

7.1We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information. Any such request can be made to [email protected].
7.2Access to personal information: If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
7.3Correction and deletion: You have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors.
7.4Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or by sending an email to [email protected]. For other marketing preferences, you can contact us via any relevant link in the marketing communication, or by sending an email to [email protected]. Information related to controlling cookies, and information related to Interest-Based and Mobile Advertising can be found in this Policy herein.

8. USE OF COOKIES

8.1Like many websites, this Website uses cookies (which may also be placed and read by third party providers, including but not limited to Google Analytics and Double Click for Publisher. Further information regarding Google partner sites can be found at the following link: https://www.google.com/policies/privacy/partners/), which are files that collect data and store information on your hard drive. Cookies are used for purposes that include but are not limited to allowing the user of such information or the website to identify account holders, track new users, record session information, and generally to optimize your experience. For online advertising campaigns, cookies are automatically deleted after a period of time that can be provided upon request to [email protected].
8.2Most browsers accept cookies automatically but if you choose you can disable the cookies from your browser, you may find that certain functions and features will not work as intended on the Services.
8.3We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: http://www.aboutcookies.org/ or http://www.allaboutcookies.org/.

9. Use of third party analytics and tracking pixels

9.1This Website uses third party analytics (“Third Party Analytics”). Third Party Analytics use cookies and/or text files to analyze website traffic. Information generated by cookies with your details (including your IP address) is transferred to servers operated by Third Party Analytics. Third Party Analytics process this information to evaluate your use of this Website, compile reports about this Website’s activity on our behalf, and deliver other related services regarding website and Internet use. Third Party Analytics may also share this information with third parties insofar as this is necessary or if these third parties process the information on behalf of them.
9.2You may disable the cookies from your browser by adjusting your browser settings. However, in this scenario, you may not be able to make full use of all the functions available on this Website. By using this Website, you agree to Third Party Analytics processing of the type of information discussed in the manner contemplated in this Policy. To the maximum extent permissible by applicable law, us, and our respective suppliers, and any of our owners, officers, directors, managers, members, agents, and employees, are not liable for any direct, indirect, punitive, incidental, special, or consequential damages or loss (including, without limitation, incidental and consequential damages, lost profits, or damages resulting from lost data or business interruption) arising out of, or in way connected with, the use of the type of information discussed in this section.
9.3Third party tracking pixels are used on our Website. This means that third parties may use cookies, web beacons, and similar technologies to collect or receive information from our Website and elsewhere on the internet and use that information to provide measurement services and target adverts. If you wish to opt out of the use of these tracking pixels please adjust your browser settings.

10. Web server & application logs

10.1Our servers automatically collect certain information to help us administer and protect the Services, analyze usage, and improve users’ experience. The information collected includes, amongst others:
  1. IP address and browser type
  2. Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
  3. Device operating system and other technical facts
  4. Pages visited and content viewed, stored, and purchased
  5. Information or text entered
  6. Links and buttons clicked
  7. URLs visited before and after you use our Services

11. Third Party Advertisers

11.1We allow third party advertising networks to serve advertisements on our behalf.
11.2Third party advertisers may place cookies on the browsers of visitors to its website(s) and may send its own cookies to the visitors’ cookie file. The cookies will allow these third-party advertisers to apply their personalized retargeting technology and to serve personalized banners; third party advertisers may collect and use this data in accordance with all applicable laws and regulations (including but not limited to laws governing privacy, and data protection).
11.3Third party advertisers will have their own Privacy Policy’s and these will be available on their websites. For further information on what third party advertisers we use for our Website please contact: [email protected].

12. Interest-based advertising (ibA)

12.1Interest-based advertising (IBA) allows us to deliver targeted advertising to users of our Services. IBA works by showing you advertisements that are based on the type of content you access or read. For example, as you browse our Services, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests.
12.2If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive advertising when you are using our Services. It just means that we will not use information collected about you for IBA and that any advertising you see will not be customized or relevant to you. You can exercise your online advertising choices at http://optout.aboutads.info or by clicking the AdChoices icon in an ad and following the instructions. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative's (NAI) Opt Out Tool (http://www.networkadvertising.org/choices) and in the EU at http://www.youronlinechoices.com/. Remember, if you delete cookies, use a different device, or change web browsers, you may need to opt out again.
12.3Mobile devices have an identifier that gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. Another tool you can use to control advertising on your mobile device is the AppChoices App: http://youradchoices.com/appchoices. You may also choose to turn off location tracking on your mobile device. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising. You may still see the same number of ads but they may be less relevant because they will not be based on your interests.

13. Links AND connections to AND USE OF OTHER third-party services

13.1Our Services may contain links to and may be used by you in conjunction with third-party apps, services, tools, and websites that are not affiliated with, controlled, or managed by us. Examples include but are not limited to Facebook, LinkedIn, Twitter® and, third-party apps like voice software and readers. The privacy practices of these third parties will be governed by the parties’ own Privacy Statements. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to these third-party services.
13.2Information that you provide to third-party companies is not covered by this Policy.

14. privacy of minors

14.1Our Services are not aimed at individuals under the age of eighteen years old (“minors”). If, however, we collect and use information about any minor, we will comply with the applicable laws.
14.2We hereby prohibit all Minors from the use of any website or service governed by this Policy, which includes those websites and services operated or provided by the SOPAM.

15. Business transfer

15.1Information obtained pursuant to this Policy, including Personal Information, may be transferred as part of any merge, acquisition, sale of company assets, or transition of service to another provider, as well as in the unlikely event of any insolvency, bankruptcy, or receivership in which the information pursuant to this Policy would be transferred to another entity as a result of such a proceeding, you acknowledge and accept that the information pursuant to this Policy may form part of the transferred assets. You further acknowledge and accept that the acquirer or successor to SOPAM Company may continue to use the information pursuant to this Policy, in the manner set forth in this Policy.