WHO WE ARE

MYREVVA LIMITED is committed to ensuring your privacy is properly protected. Revva is a social media platform which enables: (a) `"Creators`" to share and monetize their own content (b) `"Fans`" to subscribe to, and view, the content of Creators. Creators can also subscribe to, and view, the content of other Creators. Both Creators and Fans are called “Users”. This Privacy Policy applies to Revva apps, websites, software and related services (Platform) accessed via any platform or device that links to this Privacy Policy.

ABOUT THIS POLICY

This Privacy Policy explains how we collect, use, and retain data. It also contains an explanation of your rights. The Policy is written in simple language to make our practices easier to understand.

We process your personal data when you use our Revva app and website (Platforms) located on www.myrevva.com and for the provision of any services that we may offer from time to time via our Platforms. We are a "data controller" of the personal data that we process through the Platforms. This means that we decide the reasons why we process personal data about you and how we do so. However, through this Policy, we inform you about those personal data that we process and how we process them.

Please review this Policy to understand how we process your personal data. By using our Platforms, you acknowledge that you have read, understood and agree to our collection, storage, use and disclosure of your personal data as described in this Policy.

WHAT IS PERSONAL DATA

Personal Data means any data relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical data, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM, Personal Identifiable Information (PII) and others.

In addition, we may collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as de-identified, aggregated or anonymised data. This type of data is not personal data and our use of such data is not subject to this Policy.

APPLICABILITY OF THIS POLICY

This Policy is applicable to every User of the Revva Platform.

THIRD PARTY LINKS

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you.

We are not responsible for, and this Policy does not apply to, the content, security or privacy practices of those other websites, plug-ins or applications. We encourage you to view the privacy and cookie policies / notices of those third parties to find out how your personal data may be used. You can control how much of your data social media websites make public by visiting these websites and changing your privacy settings.

DATA WE COLLECT

We collect data such as name, username, password, and date of birth (where applicable), email address and/or telephone number,means of identity verification data you disclose in your user profile, and your photograph or profile video upon registration. Others include comments, hashtags, messages, live streams, and reviews, and the associated descriptor data, such as when, where, and by whom the content was created (“User Content”). Non-user’s data may appear through User Contents created or published by users on the Platform.

We also process data gotten as a result of campaigns, adverts, research, promotions sponsored or conducted by us.

We also collect data from mobile devices for a better user experience, although these features are completely optional:

• Phonebook (Contacts list): Your contacts list allows our service to be much more easy to use by the user.
• Camera (Pictures and Videos): Granting camera permission allows the user to upload any picture and video straight from our service. You can safely deny camera permissions for our service.
• Photo Gallery (Pictures and Videos): Granting photo gallery access allows the user to upload any picture or video from their photo gallery. You can safely deny photo gallery access for our service.

This data may be collected using the following methods:

• Creating an account.
• Cookies and Tracking Technologies.
• Analytics tools
• Surveys and Feedback forms.

HOW DO WE USE THE PERSONAL DATA WE COLLECT?

Any of the data we collect from you may be used in of the following ways:

• To personalize your experience (your data helps us to respond better to your individual needs and to analyze user’s behavior, preferences and interactions to curate and display content that is mostly likely to be engaging for you).
• To enhance your experience as a user. This includes showing relevant content, suggesting connections and customizing features based on the user's interest and interactions.
• To Improve our service (we continually strive to improve our service offerings based on the data and feedback we receive from you).
• To facilitate communication between users, such as directing messaging, comments and reactions.
• To improve customer service (your data helps us to more effectively respond to your customer service requests and support needs)
• To process transactions (When money is paid to subscribe for a User’s content, we process data relating to the payment transaction).
• To help users customize their profiles with data about their interests, work and more.

DO WE SHARE THE DATA WE COLLECT WITH THIRD PARTIES

We may share your data with the following:

Professional Advisers: We employ the use of advisers such as legal advisors, bankers, auditors, accountants, insurers and consultants. The lawful basis for this is that these professionals will process personal data where it is necessary for our legitimate interest of providing professional services to us.

Service Providers: Information is provided to service providers such as cloud service providers, IT, payment processors and transaction fulfillment providers. The lawful basis for this is that it is necessary to share data with these recipients in our own legitimate interest. We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the service in a shared location, and type of device used to visit the service.

Advertisers and Measurement Partners: Data is shared with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We are not responsible for the privacy practices of these third parties, and the data practices of these third parties are not covered by this Privacy Policy. They may aggregate data about our advertising and what you see on the service and then provide auditing, research and reporting for us.

Corporate, Sale, Merger or Other Business Transaction: We may disclose your data to third parties in the case of a possible sale, merger, acquisition or partnership, reorganization or restructuring exercise. In such transactions, user data may be among the transferred assets. The lawful basis we rely on for sharing personal data with these recipients is that it is necessary for our and the relevant third parties' legitimate interests.

Regulators, Legal and Relevant Authority:We share your data with relevant regulatory authorities such as the Nigeria Data Protection Commission (NDPC) and other relevant authorities in compliance with legal obligations, processes and requests. These recipients will use your personal data in the performance of their regulatory and law enforcement role. This is also reasonably necessary to enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation. To detect, prevent or otherwise address security, fraud or technical issues. Data is also shared with these regulators and organizations to protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.

We may, in our sole discretion, take necessary or appropriate steps in order to respond to claims, legal processes (including subpoenas), to protect our rights and interests or those of a third party and/or the safety of the public or any person, and/or to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

LAWFUL BASIS FOR PROCESSING

By obtaining your consent or where necessary for the performance of a contract or where legitimate interest is involved, we have a lawful basis to process data which make up the personal data of users of the Platform.

CAN I UPDATE OR CORRECT MY DATA

Users have the right to request the restriction of certain uses and disclosures of personally identifiable data as follows. You can -

1. Delete/Deactivate account settings.
2. Update or correct your personally identifiable data
3. Change your preferences with respect to communications and other data you receive from us
4. Delete the personally identifiable data maintained about you on our systems (subject to the below paragraph)

-By canceling your account, such updates, corrections, changes and deletions shall have no effect on other data that we maintain, or data that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change and deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account data at all times. You should be aware that it is not technologically possible to remove each and every record of the data you have provided to us from our system. The need to back up our systems to protect data from inadvertent loss means that a copy of your data may exist in a non-erasable form that may be difficult or impossible for us to locate. Promptly after receiving your request, all personal data stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

HOW DO WE PROTECT YOUR DATA

We take precautions to protect the security of your data. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security and correctly use your data. Notwithstanding, neither people nor security systems are foolproof including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal data, we cannot guarantee its absolute security. In the event there is any applicable law that imposes any non-disclaimable duty to protect your personal data, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

We implement a variety of security measures to maintain the safety of your personal data. We offer the use of a secure server such as Mongo DB and AWS, Encryption using 256-BIT. All supplied sensitive/credit data is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep such data confidential. After a transaction, your private data is never kept on file. We cannot, however, ensure or warrant the absolute security of any data you transmit to us or guarantee that your data on the Service may not be accessed, disclosed, altered or destroyed by a breach of any of our physical, technical or managerial safeguards, as we use third parties to process payments transactions.

YOUR RIGHTS REGARDING PERSONAL DATA

As a data subject, you have certain rights regarding the collection and processing of your data. To exercise these rights, you may contact us through [email protected]. You may be afforded certain rights under applicable laws, which may include the right to give and withdraw consent. The withdrawal of consent would not affect the lawfulness of any processing that was carried out before the consent was withdrawn. It also includes the right to request an access to, a deletion of, the correction of, a transfer of and/or a restriction of your personal data by suspending the processing of your data. You have the right to lodge a complaint with a data protection regulator. You also have the right to object to processing of your personal data where we are relying on a legitimate interest for the processing and there is something about your particular situation which makes you want to object to processing on this ground. You can edit your data, or delete your profile through the app. You can also delete any content that you uploaded to the Platform.

You can contact us to exercise any of your rights through our contact details as provided in this Policy. Please ensure that you provide sufficient data about your identity and your request. We might request additional data from you to confirm and verify your identity as an inability to do this might lead to a refusal of your request.

Where a third party makes such requests on your behalf, we would need proof such as an Authorization Letter signed by you authorizing the third party to act on your behalf.

RETENTION OF PERSONAL DATA

We would only retain personal data for as long as is necessary. This is also because they would be necessary for the purpose for which they are collected as stated in this Policy. As soon as they are no longer needed for the purpose for which they are collected, they would be deleted within a 6 months window from the day of the account deletion. We also delete personal data in compliance with legal requirements. When the legal retention periods have elapsed, such data would no longer be stored or preserved. They would either be destroyed, anonymised or archived. The determinant factors for the determination of which data would be retained and how long it would be retained for would be determined on a case to case basis. This is also the case for anyone that we share your data with and who carries out services on our behalf.

USER ACCOUNTS

When it comes to verifying user identity during the account creation process, we prioritize security and compliance. We may collect Know Your Customer (KYC) data, including National Identification Number (NIN), Bank Verification Number (BVN), and account number. This data collection helps us ensure a safer and more trustworthy environment for all users.

Updating and Deleting Account Information:

We understand that your personal data may change over time. To provide you with control over your data, you can easily update your account details through the profile settings page. Furthermore, if you wish to exercise your right to delete or deactivate your account, you can do so through the designated Delete/Deactivate Account page.

Password Security and Account Access:

The security of your account is of utmost importance to us. To enhance security, we implement Two-Factor Authentication (2FA) login, which adds an extra layer of protection to prevent unauthorized access. Additionally, we use email alerts to keep you informed about any account-related activities, ensuring that you're always aware of your account's status.

We prioritize your privacy and security, aiming to provide you with a secure and seamless experience on our platform

USER GENERATED CONTENT

Users are allowed to upload similar content on other competing platforms as the contents are not exclusive to our platform.

We also acknowledge that users contribute to our platform by generating various forms of content. However, our ownership claims over user-generated content are limited and subject to specific circumstances. We emphasize that our ownership assertions are applicable solely to content that is openly accessible and not restricted by a paywall. In instances where the content creator has expressly granted us full rights over its usage and potential revenue generation, there shall be a shared ownership arrangement with respect to the revenue generation.

It's important to note that our ownership stance is contingent upon the content falling within the criteria of being freely accessible and the creator voluntarily relinquishing their rights as per the terms outlined. We respect user privacy and their contributions, and any ownership arrangement will strictly adhere to the conditions specified by the content creator. For content that is monetized or subject to restrictions, ownership remains with the respective creators, and we will not assert any rights over such content.

This approach underscores our commitment to transparency, fairness, and privacy in how user-generated content is managed within our platform.

PAYMENT AND REVENUE OPTIONS

At Revva, we employ the Paystack payment platform to facilitate seamless transactions, particularly when it comes to payouts to our content creators. This ensures a reliable and secure payment experience for all parties involved.

Income Generation for Creators:

Creators on Revva have the opportunity to generate income through a split revenue payment model on their content. This means that they receive a portion of the revenue generated by their content's interactions.

Inclusivity of VAT and Processing Fees:

It`'s important to note that the fees charged by Revva are exclusive of Value Added Tax (VAT) and processing fees. Any applicable VAT and processing fees will be added separately.

User Banking and Card Data:

We collect and store users’ banking data for payment processing purposes. Additionally, we collect users' card data; however, it's important to clarify that while we collect this data, we do not store it for security reasons.

Payment Platform Compliance for Internal Users:

Please be aware that our payment platform does not manage compliance for internal users. Compliance with relevant regulations and policies remains a shared responsibility between users and Revva.

Our commitment is to transparency and security in all payment and revenue-related matters on our platform, ensuring a trustworthy environment for our users.

COOKIES

We use “Cookies” to identify the areas of our Services that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your usage. We use Cookies to personalize the Content that you see on our Service.
Note, we never place personally identifiable data in Cookies.

ASSISTANCE AND CONTACT DATA

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact [email protected]

AGE RESTRICTION

The age restriction for the use of our Services is 18 years of age at the minimum.

Revva does not knowingly collect any Personal Identifiable Information from people under the age of 18. If you think that your child provided this kind of data on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such data from our records.