Pukena Privacy Policy 

Pukena Platform ("Pukena", "Us" or "We") manages the information that We collect from Users in accordance with all applicable privacy legislation in Nigeria. This Privacy Policy describes how Pukena handles your personal information, and sets out the rights and obligations that both Users and Pukena have in relation to a User’s personal information. By accessing www.Pukena.com (the "Site") a User accepts and agree to the terms and conditions of Pukena's user agreement ("User Agreement"), which includes his/her consent to, and authorization of, the collection, use and disclosure of the User’s personal information in accordance with this Privacy Policy. Note that under Pukena's terms and conditions of use, you must not use the Site if you are under 18 years old. 

1. Collection and Use of Your Personal Information 
Pukena provides a unique, innovative, community-based online outsourcing service. A failure by a User to provide information requested by us may mean that We are unable to provide some or all of our services to you. Pukena collects personal information when you register with Pukena. This may include, but is not limited to, a User’s name, address, phone number, contact details, birth date, gender, credit card and account details, occupation and interests. We might also give you the option of providing a photo or video to be associated with your Pukena user ID. If a User’s personal details change, it is the User’s responsibility to update his/her Pukena account with those changes, so that we can keep our records complete, accurate and up to date. A User is not anonymous to us when s/he log into the Site or post any content (including task, bids, comments or feedback) on the Site or any associated forum. To enable us to improve our existing services and to create new service features, Pukena may collect, and share with other users and service providers on Pukena, information about the way you use our services, including (but not limited to) the transactions you enter into on the Site, your feedback rating (including any references requested using our 'Reference' feature), the comments a User post, and the transactions you enter into with our valued affiliate service providers. 

When a User: 
• Use the Site to post a task , or make a bid, or comment on a bid, or provide feedback on other users; or  otherwise communicate in a public forum on the Site, your user ID and all the material that you post is visible to other Pukena users and is also publicly available to other internet users. We strongly encourage Users to use caution and discretion when posting. 

Pukena does not in any way control, and does not accept any responsibility or liability whatsoever for, the disclosure or use of personal information which is voluntarily posted by a User in any publicly accessible area of the Site. 

Pukena may also receive and record information from a User’s internet browser and computer, including IP addresses, cookies, software and hardware attributes and your page requests. In addition to data collected from your submissions, we may also collect data on a User’s internet behavior from Facebook, other social media sites, and other services. If you use a location- enabled Pukena service, We may collect and process information about your actual location (for example, GPS signals sent by your mobile device). We may also use a range of different technologies to confirm your location. Pukena may use the information collected by it to provide the Pukena Services, including (but not limited to): 

• Identification and authentication; 
• To protect Pukena and the users of the Site; 
• To customise the content and any advertising displayed on the Site; 
• To provide, maintain, protect and improve our services; 
• Providing your information to a user with whom you have or had a contract facilitated by Pukena; 
• As required by law, order of a court, tribunal or regulator or if Pukena reasonably believes that the use or disclosure of the information is reasonably necessary for enforcement related activities; 
• To develop new service features; 
• To ensure that Pukena receives payment of the fees due to it; • to contact you (for example, to inform you about upcoming changes or improvements to our services); 
• To conduct research; 
• To permit content on the Site (such as postings or third party advertisements) to be targeted, on an aggregate basis, to the users for whom it is most likely to be relevant; • to expand our user base; 
• To develop our relationships with affiliate service providers; • to provide or arrange internal or external verification services obtained by you via the Site; and 
• To generate data reports on an aggregated, non-personally identifiable basis, for both internal and third party use, but subject to any applicable laws (for example, We may show advertisers or investors trends relating to the general use of Pukena's services). 

A User’s contact information may also be used for accounting, invoicing and billing purposes, marketing purposes, by third party service providers to Pukena, and to respond to any enquiry the User make, in some cases information we collect is transferred overseas. 

When you contact Pukena, We may keep a record of the communication(s) between a User and Pukena to help resolve any issues you might have. If other user(s) of the Site already have your userID (or other information identifying you), and you have chosen to upload a photo or other personal information to your Pukena account, We may show those user(s) that personal information. 

In certain circumstances We will use your email address to administer our User Agreement (for example, We may notify you of a breach, or action a request for a Take Down Notice in response to a claim of copyright infringement). If We collect, use or disclose any information from you that is not personal information, but is sensitive information (such as information relating to police checks conducted on users of the Site), then We will seek consent directly from you each time we collect, use or disclose your sensitive information, including for direct marketing purposes. We will not use or disclose your sensitive information for any other purpose unless the purpose is directly related to the primary purpose for which your sensitive information was collected. 

2. Cookies and Anonymous Identifiers 
If a User registers on the Site then his/her computer or device may store an identifying cookie or anonymous identifier, which can save the User time whenever he/she re-visit the Site, by accessing a User’s information when s/he sign-in to Pukena. Pukena may use cookies and anonymous identifiers for a number of purposes including to access a User’s information when s/he sign in, keep track of his/her preferences, direct specific content to him/her, report on Pukena's user base, and to improve Pukena's services. We may also use cookies or anonymous identifiers when you interact with our affiliate service providers (for example, when you integrate your Pukena account with your Facebook profile). If a User changes the settings on his/her internet browser to block or restrict cookies (including cookies associated with Pukena's services), or to indicate when a cookie is being set by Pukena, the Pukena Services may not work as intended. 
A User should remember that, while s/he may still be able to use the Site if his/her cookies are disabled, our services may not function properly on the User’s device and s/he may not be able to take advantage of certain Pukena features. 

3. Protecting and Maintaining Personal Information 
A User’s account is protected by a password for his/her privacy and security. We will take all reasonable steps to protect the information We hold about a User from unauthorized access, use and disclosure, however We cannot guarantee the absolute security of that information, or that our systems will be completely free from third party interception or are incorruptible from viruses. We cannot and do not guarantee that information you send from your computer to us over the Internet will be protected by any form of encryption (encoding software). In light of this, We cannot and do not ensure or warrant the security or privacy of your personal information, including payment and account details. You transmit your personal information to us at your own risk. You are entirely responsible for maintaining the security of your passwords and/or account information. 

4. Third Parties 
The Site may contain links to third party websites including the networks of our valued affiliate service providers, advertisers, and Paystack, or make available services obtained from third parties, including verification services by third party verification providers. If a User follows a link to any of these websites, or use any services obtained from third party service providers via the Site that requires s/he to provide personal information (including sensitive information if relevant) directly to such third parties (for instance third party verification providers), note that they have their own privacy policies. If you use our Site to link to another site, or use a service obtained from a third party service provider via the Site, the User will be subject to that site's or third party's terms and conditions of use, privacy policy and security statement. We strongly encourage Users to view these before disclosing any of his/her personal information on such sites. Pukena does not control, and does not accept any responsibility or liability for, the privacy policy of, and use of personal information by, any party other than Pukena, including any user of the Site, the operators of any website to which the Site links, or third party service providers to whom a User directly provides his/her personal information (including sensitive information if relevant) to. Third-party vendors, including Google, may show Pukena ads on sites across the Internet. The Pukena website and Mobile Apps make use of the Google Maps API to assist with location based information. More information about the Google Maps API and the related privacy policy can be found here http://www.google.com/privacy.html For the avoidance of doubt, if you use any verification services made available by Pukena via its Site, that is not performed by Pukena but a third party verification provider, then any personal information (including sensitive information if relevant) that a User provide as required by that third party in order to perform its verification services, will be collected directly by the relevant third party verification provider and will not be collected, handled, stored or otherwise used by Pukena. Pukena will only receive a User’s verification status from the third party verification provider (for example, 'granted' or 'not granted' or such other like status) in order to issue any relevant Verification Badge on the Site. The use and handling of personal information (including sensitive information if relevant) remains the responsibility of the third party verification provider under its own privacy policy. 

5. Marketing 
When a User registers on the Site, s/he may be given the opportunity to elect ("opt-in") to receive updates on our latest services, news and special offers, and those of our valued affiliate service providers ("Marketing Material"), via your Pukena account, personal e-mail address, post or telephone. If a User concludes a transaction on the Site, s/he may also be given the opportunity to opt- in to receive Marketing Material from Pukena and our valued affiliate service providers. Once a User opt-in to receive Marketing Material, s/he may, at any time, opt-out of receiving Marketing Material. To opt-out go to the 'Manage Account' link on the Site, choose 'Settings', then 'Alerts' and update your preferences. A User can also click on the "unsubscribe" link in any email containing Marketing Material that We send you, or s/he can request an opt-out by emailing Pukena using the contact information provided on the Site. If you no longer consent to receiving Marketing Material then you must opt-out in one of these ways. Pukena may contact a User as the result of a referral by another user of the Site who has provided us with contact information, such as your name and email address. The use of contact information received in connection with a referral will be governed by this Privacy Policy. You may, at any time, opt-out of Pukena's referral system by emailing Pukena using the contact information provided on the Site Pukena uses Remarketing with Google Analytics to advertise online. Using the Ads Settings in a personal Google account, visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads. Marketing Pukena and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on someone's past visits to the Pukena website. Using the Ads Settings in a personal Google account, visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads. 

6. Administrative Communications 
Pukena reserves the right to send a User administrative and account-related messages that he/she may not opt-out of. To cease all communications to a User from Pukena , a User must close down his/her Pukena account. 

7. Accessing Personal Information 
We will allow a User, at any time, to access, edit, update and/ or delete the personal information that We hold about him/her, unless: • We are legally permitted or required to deny him/her access to, and/ or to retain, the information; or • a User makes request(s) that are unreasonably repetitive, require Pukena to make a disproportionate technical effort (for example, to develop an entirely new system), risk the privacy of others, or would be highly impractical to comply with. If a User wishes to access the personal information We hold about him/her, or to delete his/her Pukena account, you should contact us. We need to prevent information in our systems from being accidentally or maliciously destroyed. This means that, where you delete information from our services, residual copies of that information on our active servers, as well as any corresponding information on our back-up systems, may not be immediately deleted. 

8. Privacy Concerns 
If a User has concerns about how We handle his/her personal information or require further information, please email Pukena using the contact form provided on the Site. If a User makes a formal written complaint in relation to our compliance with this Privacy Policy, We will contact him/her to follow up on that complaint. Other than material that a User voluntarily choose to post on the Site (such as Sender postings, bids and comments on other users), the only information about a User that We will post publicly is his/her Pukena public profile. Pukena may, from time to time, modify this Privacy Policy (and update the web page on which it is displayed). Pukena will send notification of any such modification to a User’s Pukena account and/or his/her registered email address. A User should check that account regularly.