PRIVACY POLICY
Last modified September 11, 2018
Identity
Custodian Network is the registered Business Name operating in Ghana. The name custonet.com is the trademark for the official website and mobile app of Custodian Network. Custodian Network and custonet.com may be used interchangeably in this document where the context so required. ‘We’, ‘Us’, and ‘Our’ in this document refer to Custodian Network or custonet.com.
We, at Custodian Network, (the “Company”), understand you want to keep your information private and that you value our emphasis on keeping your information safe and discrete. We respect your privacy and are committed to protect the privacy of our users (“user” or “you”).
The Company provides its services to you when you use its custonet.com services, including custonet.com mobile applications website, and when you use online services, websites and applications of our trusted third parties' brands' (each a "Brand"), as well as any of our online services )collectively: the “Services”).
We have created this Privacy Policy to inform you about how the Company and its Brand owners (if applicable) (collectively "we", "our" or "us") manage, collect and use your information through your use of our Services, which provide you a platform to share your thoughts and commentaries (as a writer) and to enjoy online information we provide be it events, news, updates, videos, podcasts, etc. (as a visitor).
The Privacy Policy is a part of our Terms of Use and is incorporated therein by references. The definitions in the Terms of Use apply to this Privacy Policy unless stated otherwise.
We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to this Privacy Policy.
In this Privacy Policy you will read about:
Types of information we collect
What type of information we collect
We collect two types of data and information from our users:
The first type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”), which includes the following:
Voluntary information: We collect information which you provide us voluntarily, such as your name, email address and mobile contact, which you may provide us as part of becoming an Author or Commentator on our online platforms (Website and Mobile App). In addition, we may also when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, we may also collect such information.
User Content: We permit you and other users to upload, post or otherwise make available data, text, graphics, statuses, links, images, comments, articles, podcasts and conversations ("User Content ") on the Services. Such User Content may include Personal Information. We as well as other users may see and share any of your User Content that you make publicly available through the Services. To learn more about User Content and your responsibilities with regard to such content, please see our Terms of Use.
Social Networks: When you log-in to our Services from your social network account (such as your Facebook account), we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends' list, as well as information you made publicly available on such account. We will use the Personal Information for the purposes set out herein and disclose such information only to third parties as detailed in this Privacy Policy.
Device information: When you are using the Services, we may collect your device persistent identifier (e.g. IMEI, MAC address, etc.) and your IP address.
The second type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected. Such information includes the following:
Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name from which you linked to the Services; etc.).
Analytics information: We collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, installs, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose.
If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
Cookies and Google Analytics
We use cookies, web pixels and other technologies or methods of web analysis to gather, store, and track certain information related to your visit to and activity through the Services.
A Cookie is a piece of data stored on your browser containing information about your access to the Services. We and our trusted partners may use such cookies for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. When you visit our site, two types of cookies may be set on your computer. The cookies set by us are called First Party Cookies. Third Party Cookies are the cookies set by someone else, such as service providers who help us operate and improve our site.
First Party Cookies
Our cookies are limited to authentication and basic service provision purposes:
Our cookies contain an alphanumeric string allowing us to identify your device which does not contain any personally identifying information about you
Third Party Cookies
In addition to these first party cookies, you may also encounter cookies set by third parties for various purposes such as those specified below. Because we frequently update our site and Services, add/ remove site features and change service providers on a regular basis, the identity of the third party serving cookies may change from time to time. We expect, however, that the following categories of third party cookies will typically be set by third parties when you use our site and Services, depending on how you interact with our Services:
Content Recommendation Cookies: Cookies set by service providers who recommend additional content to you while browsing our website;
Fraud Detection Cookies: Cookies set by service providers in order to detect fraud and improve the security of our online communications;
These cookies will expire when set by the respective third party service provider.
Google Analytics and Display Advertising
We are currently using Google Analytics on our site and have implemented the following Google Analytics features based on Display Advertising:
You can opt-out of Google Analytics for Display Advertising and customize Google’s Display Network ads by using Google’s Ads Settings (https://www.google.com/settings/ads). Google also offers additional tools which you can use to manage opt-outs for Google Analytics (https://tools.google.com/dlpage/gaoptout).
By accessing and using the Services, you consent to the placement of cookies and other tracking technologies (e.g. pixels) on your device in accordance with this Privacy Policy. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of the Services may not operate properly and your online experience may be limited. Additionally, for legitimate security reasons, we may refuse access to specific website content unless you accept the use of a cookie or similar device.
How we use the information we collect
We use and share Personal Information in the manners described in this Privacy Policy. In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:
Sharing of Personal Information
We do not trade, sell, or otherwise share your Personal Information with third-parties except as set out in this Privacy Policy.
In addition to the different uses listed above, we may transfer or disclose Personal Information to Brand owners, subsidiaries, affiliated companies and subcontractors. In addition, we may transfer or disclose Personal Information with other trusted third party service providers or partners, who are located in different jurisdictions across the world, for the purpose of:
(a) storing or processing such information on our behalf;
(b) assisting us with our business operations and the providing and improvement of our Services; and
(c) performing research, technical diagnostics and analytics with regard to the Services.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to:
We may also share Non-personal Information or anonymized information with other third parties for different purposes, such as advertising (see below specific information with regard to our advertising practices, under "Advertisements").
Data Protection Center
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to misuse our Services or acted in an inappropriate or unlawful manner, please contact our Data Protection Officer (“DPC”) at this email address: solution@custonet.com and our DPO shall investigate promptly.
Please also contact our DPO if you would like to receive information about Your Personal Information which we retain, to update it or to withdraw any consent which has been given by you under this Privacy Policy.
Third Party Collection of Information
Please keep in mind that this Privacy Policy does not apply to any third party’s websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services. You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
Advertisements
We may use advertising technology to serve advertisements (including targeted ads) when you use our Services. This technology may use Non-personal Information with regards to your use of the Services to serve advertisements to you. We may also use third parties and share with them Non-personal Information to assist us in evaluating the success of our advertising campaigns and help us retargeting our users.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp and www.aboutads.info/choices.
How do we Safeguard and Transfer your Information?
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, please contact our DPO at support@custonet.com
If you are unsatisfied with our response, you can reach out to the applicable data protection authority.
For how long we retain the information we collect?
We value your privacy and control over your Personal Information, and therefore you may, at any time, request to change and update it by emailing us at please contact our DPO at support@custonet.com
You can also request that we will correct errors or that we will erase your Personal Information (except for data that we are required to keep under applicable laws) by emailing us.
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Corporate Transaction
We may share Information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company or the Brand owner (as applicable). In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.
Minors
The Services are not designated to users under the age of 13. If you are under 13, you should not use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user under the age of 13 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact our DPO at support@custonet.com
Advertising ID
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we will collect and use it for advertising and user analytic purposes.
By downloading or using our Services you explicitly agree that we may associate your Advertising ID with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID, we will use other identifiers.
Updates
We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted in our application. We encourage you to review this Privacy Policy regularly for any changes.
Your continued use of the Services, following the notification of such amendments in our application, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
How to contact us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact our DPO at support@custonet.com