Privacy Policy

MOBIN PRIVACY POLICY  

Introduction:

This is the Privacy Policy Statement of Mobin Network Ltd including all Mobin Network brands (all hereinafter referred to and described as “Mobin”, Mobin Media, Mobin News, Mobin TV, Mobin Films, Mobin Productions, “we”, “us” or “our” where the context so admits).

We are guided by our values, vision and mission including our editorial methodology in the use of personal data. We uphold the law on confidentiality of personal data as required under the Nigerian Data Protection Act 2023, the Nigerian Data Protection Regulation (NDPR), and the General Data Protection Regulation (GDPR). We are committed to keeping your personal data safe and confidential. To complement our global approach to privacy data protection, this policy also incorporates specific information privacy rights granted to individuals under the EU Privacy Law, the USA, and UK Privacy Laws. This reflects our relationship with our readers and followers in these locations where our news reports are made available.

We are very careful in the use of personal data. The details of how we use and protect your privacy is stated in this Policy covering the following topics:

  • Information about your rights, the choices available to you, and our obligations in the USA, UK, Ireland, Nigeria, and elsewhere.
  • Transparency about how we collect and use your personal data, including when and how it is shared.
  • Information on how we protect your personal data.
  • Information on how we will facilitate your rights and respond to your questions.

About this Privacy Policy Statement

This privacy policy explains how we collect, use, and share your personal data when you use the services provided on our websites or interact with us. This privacy policy also explains your data privacy rights.

Personal data is any information about you by which you can be identified or be identifiable. This can include information such as:

  • Your name, date of birth, gender, email address, postal address, phone number, mobile number, or financial details, such as payment cards you use to purchase products or subscriptions or to support our journalism.
  • Information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based).
  • Information relating to how you use and interact with our sites and services.

When we refer to “personal data” in this policy, we are also referring to all private data as defined by the UK and USA laws.

Who We Are

Mobin Network Ltd (often shortened as Mobin) is an organization registered by the Corporate Affairs Commission Abuja with operational address at Destiny Plaza, No. 7 Airport Road, Emene, Enugu, Nigeria. The details of our services are contained in our Memorandum and Articles of Association held by the Corporate Affairs Commission Abuja. Mobin is the data controller in respect of your personal data that you share with us. This means that we are responsible for deciding how we hold and use your personal data. You can contact us directly by visiting our website and clicking on the Contact Us link.

Name of the Company:              MOBIN NETWORK LTD

Contact Information:                           mobinreports@gmail.com

Company Registration Number:         RC No. 1927795

Company Address:                    Destiny Plaza, No 7 Airport Road, Emene, Enugu, Nigeria

URL:                                         https://mobinnetwork.com

When and how we collect your personal data.

We collect your personal data when you visit our websites, subscribe for products or services, contribute, or donate to Mobin to help our media works or when you interact with us. We will only collect your personal data in line with applicable laws. We collect your personal data in the following ways:

  • Directly from you, e.g. when you sign up for our services, purchase products or services, including by signing up for our news, or movies, or subscribing to our YouTube Channels, and when you browse or use our websites.
  • Personal data we generate about you, e.g. personal data we use to authenticate you, or personal data we generate about you from your IP address or your preferences.
  • Personal data we collect from third parties, e.g. personal data that helps us to combat fraud or which we collect, with your permission.

When you use our websites, we may also use cookies or similar technologies to collect extra data, including:

  • Your IP address. This is a numerical code to identify your device, together with the country, region, or city where you are based.
  • Your geolocation data – your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data, and data about connection with local Wi-Fi equipment.
  • Information on how you interact with our services.
  • Your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites.
  • Details of your computer, mobile, TV, tablet, or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content.

We will not collect special categories of data from you such as personal data concerning your race, political opinions, religion, health, or sexual orientation, unless you have chosen to provide that type of personal data to us.

When you use our apps

The Mobin apps use personal data based on the content you have viewed. Information on bugs and crashes is also sent to us when you use our apps. A list of the articles that you have recently viewed is also cached in the local storage on your device. You can delete this reading history in the settings of the app. You can choose to receive notifications on your device via the app, and manage these notifications in the settings of the app.

Google

When you sign in to our sites using your Google login details, you give Google permission to share the personal data that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, a link to your Google profile and, if you have one, your profile picture. This email address will be linked to your profile and will be used to retrieve your subscribed content.

Personal data when you post comments about Mobin on other social media sites.

If you have mentioned Mobin in posts on social media sites, then we may collect your social media handles. For example, when you mention Mobin in a post, we may collect your X handle.

When you post publicly (comments) on our sites

When you post on a discussion platform or comment publicly on an article on one of our websites, the personal data you post, including your username and other information about yourself, are publicly accessible. This personal data can be viewed online and collected by other people. We are not responsible for the way these other people use this personal data. When contributing to a discussion, we strongly recommend you avoid sharing any personal details, including information that can be used to identify you directly such as your name, age, address, and name of employer. We are not responsible for the privacy of any identifiable information that you choose to post in our online community platforms or other public pages of the site.

How we collect personal data

We collect personal data when you:

  • Become a supporter or register for an account on our sites.
  • Make contributions or donations to support Mobin.
  • Attend our events (in person and/or virtually).
  • Sign up for our media news, emails, movies, and films.
  • Post or make comments in our online community platforms.
  • Use mobile devices to access our content.
  • Access and interact with any of our websites.
  • Contact us via email, social media, our apps, or similar technologies or when you mention us on social media.
  • Test our products, participate in focus groups, or provide us with feedback.

How we use your personal data

We use personal data collected through our sites only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.

Legal grounds for using your personal data.

The legal ground may be one of the following:

Consent: Often, we will use your personal data because we have asked for your consent, which you can withdraw at any time.

Performance of a contract with you (or to take steps prior to entering into a contract with you): We will use your personal data if we need to in order to perform a contract with you. For example, where you have purchased a subscription from us, we will need to use your contact details and payment data in order to process your order and deliver your subscription or we may contact you directly via social media or email.

Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data, for example to disclose salary details to the HMRC in the UK or similar authorities in the USA and Nigeria.

Our legitimate interests: We may process your personal data where it is necessary for our legitimate interests in a way that might be expected as part of running Mobin and in a way which does not materially impact your rights and freedoms. For example, it is in our legitimate interests for us to understand our readers, promote our services and ways to support us, and operate our sites and apps efficiently for the creation, publication and distribution of news, media, and related journalistic content both online and in print form, globally.

In addition to the above, we also rely on the legitimate interests below to use your personal data:

  • For internal administrative purposes related to our services – such as our accounting and records.
  • To inform you of any changes to our services, such as updates to our terms and conditions.
  • To enable you to share our content with others using social media or email.
  • When we respond to your queries and to resolve complaints.
  • When we moderate comments under our community standards and participation guidelines.
  • To troubleshoot technical issues on our sites and their functionalities.
  • When we de-identify or anonymise personal data.
  • For security and fraud prevention, and to ensure that our sites are safe and secure and used in line with our terms of use.
  • To contact you directly via social media or email if you send us emails or engage with Mobin on social media or contact us.

Where personal data has been de-identified or anonymised, it will not be used in order to re-identify individuals.

Mobin Media is a media organisation and publisher. Data protection law includes certain exemptions when personal data is processed for the purposes of journalism. Those exemptions apply to some of the ways Mobin uses personal data. This privacy policy does not cover personal data that Mobin processes for the purposes of journalism.

Access permissions when you are using the Mobin app.

When you use the Mobin app, we will ask for permissions to access functions of your mobile device. The time to ask for permissions will depend on the operating system of your mobile device, but can include:

  • When you decide to store content including photographs on your mobile device to read or use when offline. We will need your permission to save content to your mobile device.
  • Asking permission to access your contact details/profile on your mobile device, so that we can add or find your Mobin account on your phone.
  • If you decide to submit content, such as photographs, to Mobin. We will ask permission to access your camera or photographs.

Updating your personal data and your profile page on our sites

When you register for an account with www.mobinnetwork,com, you have access to a profile page. Under “edit profile” you can review and update what personal data is public when you comment on our articles, or if people look up your profile.  

Security of your personal data

We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage, or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential, and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending any information, including personal data, via the internet is not completely secure. We cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.

When we share your personal data

Within the Mobin Network

Depending on where you live, we may share your personal data within the Mobin Network Group which includes all Mobin brands. We may share it to perform a contract with you, for administrative purposes, or when we have a legitimate interest in doing so. For example:

With external organisations

We share your personal data with other organisations that are not directly linked to us under the following circumstances:

Service providers – We may share your data with other organisations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:

  • Online payments processors who process credit and debit card transactions on our behalf.
  • Fraud management providers that help us to identify and prevent online fraud.
  • Internet and cloud hosting services providers, such as Amazon Web Services (AWS).
  • Service providers that help us carry out analytics, facilitate audience creation and segmentation and to measure our audience engagement.
  • Service providers that help provide us with insights and analytics that help us to improve our products and services. For example, we use Google Analytics to understand how visitors engage with our sites.
  • Google ReCaptcha, which we use to protect our sites from fraudulent users.
  • Service providers that help provide online identity-as-a-service and access management services such as Okta.
  • Service providers that allow us to deliver personalised advertising to your device.
  • YouTube because we use their unbranded embedded player to provide video content on our websites and apps. The embedded player relies on the YouTube API, which is a type of software that allows data to be communicated between our website and apps and the YouTube player. We will provide this data about how you interact with videos to enable YouTube to provide statistical information such as how many views a video has, or how many users watch the entire video. More information about how YouTube will use this personal data, which includes usage data when you interact or use the embedded YouTube player, can be found at the Google Privacy Policy.

Agencies and authorities if required by law – We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else (for example, in response to a valid and properly served legal process such as subpoena or warrant). If we have your contact details, we will take reasonable steps to attempt to notify you prior to disclosing your data unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with your use of Mobin services.

Social media organisations – We may share your personal data with other organisations when our web pages use social plug-ins from these organisations (such as liking or sharing on social media). These other organisations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, personal data they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.

When we share your personal data, as specified above, with any organisation which accesses your data in the course of providing services on our behalf, they will be governed by strict contractual restrictions to make sure that they protect your data and comply with applicable law. We may also independently audit these service providers to make sure that they meet our standards.

International data transfers

Data we collect may be transferred to, stored, and processed in any country or territory where one or more of our Mobin service providers are based or have facilities. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this privacy policy.

Whenever we transfer your personal data out of the UK or the EU and European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:

  • We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
  • We may also use specific approved contracts that use Standard Contractual Clauses for the protection of personal data where appropriate, with our service providers that are based in countries outside the UK or the EEA, including those based in the USA. These contracts give your personal data the same protection it has in the UK or the EEA.

How long we keep your personal data

We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data.

How we may contact you

Service communications.

From time to time, we may send you service emails or SMS, for example, telling you about subscriptions or thanking you when you contribute or donate to support Mobin.

Marketing communications and editorial newsletters

If we have your permission or you have not opted out, we may send you materials we think may interest you, such as new Mobin offers and updates. Depending on your marketing preferences, which you can amend, this may be by email, phone, SMS, or post.

Market research

Sometimes we may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by signing into your Mobin account and going to the tab “emails and marketing”.

Responding to your queries or complaints

If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.

Your privacy and data protection rights with regard to the personal data that we hold about you.

You have a number of rights with regard to the personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:

  • You have the right to receive a copy of the personal data we hold about you.
  • You have the right to correct the personal data we hold about you.
  • You also have the right to ask us to delete your personal data or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request.
  • Where applicable, you have the right to object to processing of your personal data for certain purposes.
  • Where you have provided us with consent to use your personal data, you can withdraw this consent at any time.
  • If you do not want us to use your personal data for marketing analysis, you can change your settings in the “Data privacy” tab of your Mobin account.

If you would like to exercise any of your rights specified above, please email mobinreports@gmail.com .We will respond to all standard legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a large number of requests. In this case, we will notify you and keep you updated.

We may need verification of your identity to proceed with a request. If you provide us with proof of identity containing information that does not match our records, we may request further proof of identity from you. This is a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, for any further copies requested by you, we may charge a reasonable fee based on administrative costs.

Contact us for information about how we use your personal data.

If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at Mobin Network Ltd, Destiny Plaza, No 7 Airport Road, Emene, Enugu, Nigeria, or email mobinreports@gmail.com  

Complaints will be dealt with by the Data Protection Team and will be responded to within 30 days.

Website not for children

Our website and apps are neither intended for, nor targeted to children under 18, and we do not collect personal information directly from children under 18. We receive limited personal information about children from parents and other responsible adults only as required to establish and maintain accounts for the children’s benefit.

There are specific provisions that regulate the processing of a child’s data. A data controller has an obligation to obtain consent from a data subject’s parent or legal guardian if the data subject is a child (Section 31(1) of the NDPA). However, consent may not be required, where the processing is to protect the vital interest of a child, the processing is for educational, medical, or social care and done under the supervision of a professional, or necessary for court proceedings (Section 31(2) of the NDPA). Section 65 of the NDPA adopts the definition of a child i.e., someone below 18 years of age from the Child Rights Act 2003 (‘Child Rights Act’). Section 8 of the Child Rights Act stipulates that every child has the right to privacy, family life, home, correspondence, telephone conversation, and telegraphic communications.

Section 2.4(a) of the NDPR provides that no consent shall be sought, given, or accepted in any circumstance that may engender a child rights violation. Section 3.1(1) of the NDPR requires a data controller to take appropriate measures to provide any information relating to processing to the data subject in a concise, transparent, intelligible, and easily accessible form, using clear and plain language, and for any information relating to a child.

Changes to this privacy policy

If we decide to change our privacy policy statement, the updated privacy policy will be posted on our website. If the changes are significant, we may also choose to email all our registered users with the new details. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.

Spread the love