Privacy Policy
FRESHMINDS AGENCY respects your privacy. As such, we provide this privacy statement explaining our online information practices and the choices you can make about the way your information is collected and used. We recognize the potential of technology to help you communicate with us via our website and through e-mail and we would like to use this technology over time to develop a relationship with you. The privacy policy below details the measures taken by FRESHMINDS AGENCY CONSULTING LTD (“FRESHMINDS”) to protect your privacy in connection with your use of https://www.freshminds.ng, and other sites, online (including mobile) services and applications owned and/or controlled and/or administered by FRESHMINDS (collectively, “Site”). Please read the following to learn more about our privacy policy.
This privacy policy is incorporated into and is subject to the FRESHMINDS Terms of Use. If you do not agree to the terms of this privacy policy or the Terms of Use, DO NOT provide FRESHMINDS with any information and DO NOT use the Site. Your continued use of the Site after the privacy policy has been modified will signify your acceptance of the changes for information gathered after the date of the change.
Overview
This policy statement discloses our privacy practices including the notification of:
Personally identifiable information (“PII”) collected through our Site;
Intended usage of this PII;
Choices available regarding opt-in/opt-out, data collection, use and distribution of the information;
Security measures to protect the loss or misuse of information under FRESHMINDS’s control;
How to maintain the accuracy of your information.
The Information Collected
In general, you may visit our Site and access information while not revealing any individual user information other than Technology Related Information (defined below). If you upload or post content to this Site, the content will be governed by the Terms of Use and any other terms or conditions on the upload pages. The types of individual user information collected in the registration process may include your name, contact information, other PII and other information volunteered by you.
FRESHMINDS collects PII when you register with FRESHMINDS, when you visit FRESHMINDS pages, when you use FRESHMINDS created app and when you deliver communications or content to the Site. FRESHMINDS may combine information about you that we have with information we obtain from business associates or otherwise. Without limitation, information collected, including PII, may be used by FRESHMINDS for internal research purposes, marketing, promotions and public relations, subject only to the terms of our privacy policy.
FRESHMINDS will not disclose, transfer, sell or otherwise communicate your PII to any third party, other than FRESHMINDS’s parent, subsidiaries and affiliates, and each of (i) their employees or (ii) vendors and contractors operating under confidentiality agreements and subject to FRESHMINDS’s privacy policy, unless you give FRESHMINDS permission to do so, except as set forth in this privacy policy. Notwithstanding the foregoing or anything to the contrary, FRESHMINDS may disclose any information you provide if required to do so by law or pursuant to a request by law enforcement or if we have a good faith belief that disclosure is necessary to (1) comply with the law or with the legal process; (2) protect and defend the rights or property of FRESHMINDS or third parties; or (3) act in an emergency to protect someone’s safety or legal rights (“Mandatory Disclosures”). As we develop our business, we may buy or sell assets or change our name or form of entity, and, depending upon the transaction, your personal information may be one of the transferred assets; provided, however, we will not sell or transfer PII except subject to the terms of our privacy policy. For instance, in the event that FRESHMINDS is acquired by another company, your PII may be part of the assets transferred to the acquiring party. FRESHMINDS will notify you before PII about you becomes subject to a different privacy policy. The collected information may be provided in the aggregate to third parties, including potential business partners and advertisers, but this information is not linked to any PII before it is disclosed unless FRESHMINDS has obtained your consent.
To help administer our Site and provide a positive experience while visiting our Site, FRESHMINDS, our service providers, advertisers and partners may collect various types of non-personally identifiable, technology-related information. “Technology-Related Information” may include, but is not limited to the following: current Internet protocol address and type of browser you are using (e.g., Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the domain name of your internet service provider (e.g., Comcast, Verizon or AT&T), the web pages you have visited, sites visited before and after you visit the Site, the type of handheld or mobile device used to view the site (e.g., iPhone, Blackberry), location information, the content you have accessed and the advertisements you have been shown and/or clicked on.
Engagement through Social Media
You also can engage with our content, such as applications and other offerings, on or through third-party social networking sites, such as Facebook, and FRESHMINDS or third-party social media plug-ins and applications. When you engage with our content on or through third party social networking sites, plug-ins and applications, you may allow us to have access to certain information from your social media profile (e.g., name, e-mail address, photo, gender, birthday, location, your list of friends, people you follow and/or who follow you, the posts or the ‘likes’ you make) to deliver the content or as part of the operation of the application. We may also obtain non-personally identifiable information (e.g., content viewed and information about advertisements within the content you have been shown or may have clicked on,) from your interaction with our content.
When you provide information from your social media account, it can help enable us to do things like (1) give you exclusive content, (2) personalize your online experience with us within and outside our applications or websites, and (3) contact you through the social networking sites or directly by sending you the latest news and special offerings. By doing so, you consent to the use of this information in accordance with our privacy policy. When you provide personal information to us through an application, on our sites, or on social networking sites, it may be publicly viewed by other members of these sites and we cannot prevent further use of the information by third parties.
Through some social networking sites’ privacy settings, you can control what data you share. For more information about how social networking sites handle your personal information, please refer to their privacy policies and terms of use.
A “cookie”
is a small line of text that is stored with your Web browser for record-keeping purposes and to help us provide better service to you. Your browser has options to accept, reject or provide you with notice when a cookie is sent. We use cookies for many purposes such as to save your password so you don’t have to re-enter it each time you visit our site. We also use cookies to deliver content (which may include third party advertisements) specific to your interests. FRESHMINDS may set and access FRESHMINDS “cookies” on your computer. FRESHMINDS lets other companies that show advertisements on some of our pages set and access their cookies on your computer. Advertisers or other companies do not have access to FRESHMINDS’s cookies. Other companies’ use of their cookies is subject to their own privacy policies, not this one. FRESHMINDS has no control over the information collected from or about you by any third party after you have left the Site. By clicking on links to other websites, advertisers and other third parties, you are leaving the Site. Once you have left the Site, FRESHMINDS does not control the data collection and privacy practices, or other activities, of any third party linked to this Site and FRESHMINDS assumes no liability and is not responsible for any practices of such third party websites.
Third Party Collection
Some of our Sites contain links to or integrations with other sites such as Facebook, Twitter, LinkedIn, etc., whose information collection practices may be different than ours. Visitors should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
We also use the services of reputable third parties to provide us with data collection, reporting, ad response measurement, and site analytics, as well as to assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit or set their own cookies. We, our third party service providers, advertisers and/or partners may also place web beacons for these third parties. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this privacy statement.
Consent/Opt-Out
FRESHMINDS may consider requests from unrelated third parties to contact you, but we will not give that third party any PII unless FRESHMINDS has obtained your consent. You may give this consent by “opting-in” to having your information shared with third parties when you register. Additionally, FRESHMINDS provides you the opportunity to be sent newsletters and information about programming, promotional events, marketing events and opportunities to participate in research studies. If you would like to exercise your right under the CAN SPAM Act to not receive future e-mail correspondence from us, except with respect to your prior financial transactions or communications, regarding Mandatory Disclosures or as otherwise required by law, you may do so by using a link provided at the bottom of the aforementioned email communications. You can also send us an email at for any opt-out or opt-in purpose. You may review, change or delete any PII which you submitted to FRESHMINDS by using the update subscription preferences link provided at the bottom of an email communication from FRESHMINDS, or by contacting [email protected]. You must include a description of the information you would like to change. Alternatively, you can send mail to the following postal address: FRESHMINDS, 1 Continental Way, Off CMD Road, Ikosi-Ketu, Lagos (Attn: Privacy).
Data Security
FRESHMINDS endeavors to ensure the commercially reasonable protection of user’s PII. We have implemented security measures to protect PII collected on our Site against loss, misuse or alteration. However, the Internet is an open system and technology and human operators are not infallible. Accordingly, we cannot and do not guarantee that the individual user information you have transmitted, including PII, will not be intercepted by others and/or decrypted or accidentally disclosed. We cannot ensure or warrant the security of any information transmitted to us over the Internet, and we accept no liability for any unintentional disclosure.
Changes to the Privacy Policy
As a user of the Site, please understand that our privacy policy may change from time to time. If we decide to make any material changes, we will post these changes on the Site. It is your responsibility to check these terms periodically for changes and/or updates. If, at any point, we decide to use PII in a manner different than what was stated at the time it was collected, we will notify users of this change by email. Users will have a choice as to whether or not we use their information in this different manner. FRESHMINDS will use information in accordance with the privacy policy under which the information was collected unless you agree otherwise.
A Special Note about Children, Children’s Privacy and Our Compliance with the Children’s Online Privacy Protection Act
In compliance with the Children’s Online Privacy Protection Act (COPPA), we are a general audience site and do not intend to collect any PII from children under 13 years of age, unless we believe such collection to be permitted by law. Our Site targets an audience that is over the age of 18 and some content may not be appropriate for all ages. Parental supervision is recommended. If you are the parent or guardian of a child under 13 and believe that he or she has disclosed PII to us, please contact us at Upon request, the parent or guardian of a child under 13 may review and request the deletion of such child’s PII, as well as refuse to permit the further collection or use of such PII.
Still have Questions? If you have any questions, or believe FRESHMINDS is not abiding by our posted privacy policy, you should contact FRESHMINDS’s privacy manager by email at [email protected]. Alternatively, you can send mail to the following postal address: FRESHMINDS AGENCY, 1 Continental Way, Off CMD Road, Ikosi-Ketu, Lagos (Attn: Privacy).
Effective Date
This privacy policy was last changed and posted on our Site on September 25, 2013.