Sprech Internet Services Enterprise (Sisli)® Privacy Statement
Effective August 29, 2016
At Sprech Internet Services (Sisli), Nigeria (Sisli) (“we” or “us”), including our wholly-owned subsidiary, LLC, we respect and protect the privacy of our trialers, customers and others who use our websites, products and services. This privacy statement provides details about how your personal information is collected and used by us. Personal information is any information that identifies you or would enable someone to contact you, which may include your name, email address, phone number and other non-public information that is associated with such information. It does not include aggregate information, anonymous information or any other non-personally identifiable information. This privacy statement applies to the Sprech Internet Services (Sisli) website; www.sisli.com.ng; www.sislinigeria.com products and services that are located in other domains that we manage; and any other sites owned or operated by us and our mobile applications (the “Sites”). This privacy statement does not cover how our trialers and customers may use the data that we collect on their behalf. For information on how they use data, please contact the applicable trialer or customer directly. Sprech Internet Services (Sisli), Nigeria is located at 93 Upper Chime, New Heaven, Enugu, Nigeria.
Information Collection and Use by Us
We are the sole owner of information collected on the Sites (including any metadata), except for contact lists and content that you provide to us in connection with your use of our products and services. We collect information only as necessary to fulfill the purposes set forth in this privacy statement and we will only use this information as described in this privacy statement. We may combine any or all of this data with other information we collect about you.
In connection with your use of our products or services, we will obtain contact lists (including email addresses and other information for your subscribers) and content (including the content of your campaigns and storefront information) that you provide to us in connection with such use. We acknowledge your ownership rights in such contact lists and content. We will never sell or rent your contact lists to anyone without your permission and will never use your contact lists or content for any purpose other than as described here.
In the course of your use of our products or services or visit to the Sites, we may also obtain the following information about you:
Information that you provide during any voluntary or mandatory registration process (such as first and last name, company name, email address, phone number, billing address or credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services;
Payment information that you provide to us (on our Sites or otherwise) when you purchase some of our products and services, including credit card data;
Additional information about you that we collect from other sources, such as information you provide at seminars or to our partners, information that is publicly available or that you consent to us receiving from third parties;
Information from third party social networking sites, including information that social networking sites provide to us if you use your credentials at such social networking sites to log into some of our Sites (such as your name and email address to pre-populate our sign-up form). The information you allow us to access varies by social networking site, and it is affected by the privacy settings you establish at the social networking site. You can control and find out more about these privacy settings at the applicable social networking site;
Your telephone conversations with us (which we may monitor or record); Data relating to your activity on our Sites (such as your IP address, browser type and version, geographic location, pages you view, how you got to our Sites and any links you click on to leave our Sites, metadata about your use and your subscribers’ use of our Sites and your emails you send (including clicks and opens), your interactions with any videos we offer and any device or other method of communication you use to interact with the Sites), which we store in a variety of places within our infrastructure, including system log files, back end databases and analytics systems; and If you decide to import contacts from other email accounts, we collect the username and password for the email account you wish to import your contacts from.
We may use any of this information to offer and improve our products and services, to provide you with requested information or technical support, to facilitate your movement through the Sites or your use of our products and services, to do a better job of advertising and marketing our products and services, to diagnose problems with our servers or our products and services, in connection with our security and compliance programs, to administer our Sites, to communicate with you, to target prospective customers with our products or services, to assist us in offering you a personalized experience or otherwise tailor our Sites, product and service offerings to you, or as otherwise described in this privacy statement. We may aggregate and anonymize information received to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our Sites or evaluated or purchased our products and services. Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services. We may also use recorded telephone conversations for quality control purposes, to train our employees and for our own protection. We will only use the username and password for any email account you import any contacts from to enable you to import such contacts.
For clarity, any storefront information you make available to us in connection with our product is non-confidential for all purposes and may be made publicly available on one of our Sites (or the sites of any of our publishers).
We obtain information that is provided by you on our public forums, including the Sprech Internet Services (Sisli) Community and Sprech Internet Services (Sisli) Marketplace. With your consent, we may also obtain and post testimonials or reviews for inclusion on our Sites or elsewhere. Your posts may remain even after you suspend or cancel your account. Reviews and contributions to any of our public communities are considered public and non-confidential by us and are not treated as proprietary information or personal information covered by this privacy statement. To request removal of your personal information on our public forums or on the public portions of our Sites, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Security and Privacy
We employ reasonable technical, administrative and physical safeguards to protect the confidentiality and security of your personal information. We use industry-recognized technical safeguards, such as firewalls, and have adopted and implemented security procedures to protect your information from loss, misuse or unauthorized alteration. When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as the Transport Layer Security (TLS) protocol.
Notwithstanding our efforts, we cannot guarantee absolute or unqualified protection of this information given the open nature and resulting instability of the Internet and World Wide Web, and we make no representations or warranties as to the effectiveness of our security and assume no liability for security breaches or any failure in the security of your computer equipment, your internet service provider or other networks and communications providers.
Sharing of Information
We will only share certain personal information with our partners, third party service providers and co-marketing partners, an acquirer, with others within your organization, our affiliates (including other members of the Sisli family) and for legal reasons, as more fully described below.
We may share your name, email address and other information with certain of our partners so that they may assist you in using our products and services, contact you with offers, services or products that may be of interest to you, and provide you with their products or services. Our partners are prohibited from using your contact information for any other purpose without your consent. We will not provide our partners with your credit card information. If you are working with a partner and would like that partner to have full access to your account, we will provide access to just that partner upon your request or consent.
Occasionally, we enter into contracts with carefully selected third parties so that they can assist us in servicing you (for example, providing customer service, fraud detection and deterrence or access to advertising assets, etc), to assist us in our own activities or to engage in co-marketing activities with us. Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.
We may also share non-personal information with any third party, including the media, industry observers, marketing and advertising partners, vendors, customers, potential customers or partners. For example, we may disclose mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our Sites or evaluated or purchased our products and services.
If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information may be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our website of any such transfer and any choices you may have regarding your information.
We may share your information with others within your organization (including any affiliates or any other individuals designated as users on your account). We may also share your personal information with any of our affiliates (including other members of the Endurance corporate family). Any such affiliate may use your information only according to the terms of this privacy statement.
Lastly, we may disclose your personal information to courts, law enforcement authorities and other relevant third parties, such as internet service providers, when such disclosure is necessary or advisable, in our sole discretion, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be: violating our terms and conditions of use; causing injury or other harm to, or otherwise violating our property or other legal rights, or those of other users or third parties; or violating federal, state, local, or other applicable law. This disclosure may include transferring information to the U.S. and outside the European Economic Area. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena.
Technologies such as cookies, beacons, tags and scripts are used by us and our partners (including marketing partners and affiliates) as well as our analytics and other service providers. These technologies are used in many ways, including advertising, sales and marketing, analyzing trends, administering and improving the Sites, tracking users’ movements around the Sites (including point of entry), gathering demographic information about our user base, verifying login status, measuring the success of a particular marketing campaign, providing improved customer service, providing more relevant content, deterring or detecting fraud, and providing users with a customized experience. We also use these technologies as part of our product offerings, including to provide our trialers and customers with information about their campaigns, such as email opens, clicks and bounces and tracking whether messages are shared and opened using our social share features. We collect information based on the use of these technologies on an individual as well as aggregated basis.
We use Local Storage Objects (LSOs), such as HTML5 to, among other things, optimize screen presentation, video and other preference information. Various browsers may offer their own management tools for removing HTML5 LSOs. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 and Flash to collect and store information. To learn how to manage privacy and storage settings for Flash cookies click here.
We partner with third parties to either display advertising on our Sites or to manage our advertising on other sites. Our third party partners may use technologies, such as cookies, to gather information about your activities on our Sites and other sites in order to provide you with advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by stopping from using this website. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
You have a choice about how we use your personal information to communicate with you, and you may opt out at any time by unsubscribing or changing your preferences.
Our Anti-Spam Policy tolerates only permission-based email. You always have the opportunity to opt-out of our marketing communications with you or change preferences by following a link in the footer of all non-transactional email messages sent by us or by emailing us at email@example.com. In addition, anyone receiving emails from us on behalf of our trialers or customers always has the opportunity to opt-out of email messages from such customer or trialer by using the opt-out link included in the link in the footer of the message. If you believe that you have received an unsolicited commercial email from us on behalf of any of our trialers or customers, you may report it to us at firstname.lastname@example.org.
If you do not wish to have your personal information shared with third parties for co-marketing purposes, you may do so at any time by opting out of all marketing communications with us.
Some communications (for example, important account notifications and billing information) are considered transactional and are necessary for all of our trialers and customers. You must cancel your Sprech Internet Services (Sisli) account, as applicable, to unsubscribe from these communications. To cancel your Sprech Internet Services (Sisli) accounts, please see “Access to Personal Information” below. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.
To manage the information we receive about you from a social networking site or any other third party, you will need to follow the instructions from that party for updating your information and changing your privacy settings. The information we collect is covered by this privacy statement and the information the third party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our Sites.
If an account or profile was created without your knowledge or authorization, please contact us at email@example.com to request removal of the account or profile.
Access to Personal Information
We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access it and make corrections to it.
We will retain and use your information for as long as your account is active or as needed to provide you with services, as necessary to comply with our obligations under this privacy statement and at law, resolve disputes, enforce our agreements and for backup purposes. Notwithstanding the foregoing, we may continue to disclose your information to third parties in a manner that does not reveal personal information after you suspend or cancel your account unless you request otherwise by calling the Sisli account management team at (+234) 908 000 3016
Third Party Links and Information Collection and Use by Our Customers
Some of our Sites provide links to other websites. You may be asked to submit personal information to any of these sites. You may also be asked to provide certain personal information to our trialers or customers in connection with their use of our products and services. Because we do not control the information policies or practices of these third party sites or our trailers and customers, you should review their privacy policies to learn about how they collect and use personal information.
You may also log in to some of our Sites using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you with the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form. For example, if you take advantage of certain of our social media features, such as the Facebook Like button, and widgets, such as the “Share This” button or interactive mini-programs that run on our site, the applicable social networking sites may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable it to function properly.
Our Sites and our products and services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.
We are headquartered in the Federal Republic of Nigeria. Personal information may be accessed by us or transferred to us in Nigeria or to our affiliates, partners, merchants, or service providers elsewhere in the world. By providing us with personal information, you consent to this transfer. We will protect the privacy and security of personal information according to this privacy statement, regardless of where it is processed or stored, however you explicitly acknowledge and consent to the fact that personal information stored or processed in Nigeria will be subject to the laws of the Nigerian Government, including the ability of governments, courts or law enforcement or regulatory agencies of Nigeria to obtain disclosure of your personal information.
For the purposes of European Directive 95/46/EC and applicable national implementing laws in your jurisdiction, with respect to your data, we are a data controller and with respect to your contacts’ information, we are a data processor.
We comply with the U.S.–E.U. and U.S.-Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from the European Union member countries and the Swiss Confederation. Sprech Internet Services (Sisli) has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please Click Here.
We have designated our Privacy Manager to oversee our compliance with applicable privacy laws. Questions and inquiries concerning your privacy may be directed by email to firstname.lastname@example.org or write us:
Sprech Internet Services (Sisli), Nigeria
Behind Amara Oil & Gas
New Heaven Extension, Enugu.
Attention: Privacy Manager, Sisli
Notification of Changes
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we decide to change this privacy statement in any material way, we will notify you here, by email, or by means of a notice on www.sislinigeria.com so our users are always aware of what information we collect, how we use it and under what circumstances we disclose it. For material changes in how we use personal information, we will provide advance notice by email (sent to the email address specified in your account) or by means of notice on www.sislinigeria.com prior to the change becoming effective. In all cases, your continued use of any Site or our products and services constitutes consideration and your binding acceptance to any such changes.