Welcome to Xaron Technology Limited (“Xaron”, “Xaron”, the “Company”, or “we” or “us”), a logistics marketplace (“The Platform”) which affords end-users a seamless access to logistics service providers. On our platform, we facilitate a smooth interface between supply and demand, as end-users in need of dispatch services can find a carefully curated list of affiliated riders, capable of servicing your needs. You can read more about our offerings in our Terms and Conditions (Terms and Conditions should be hyperlinked)

At Xaron, your Personal Data is valued at a premium. Indeed, the need to protect your personal data whenever you visit our Platform is embedded into our objectives and drives our business. We have made it a point of duty to ensure adequate protection of your personal data whenever you use our platform. In view of the foregoing, we have formulated this privacy policy to inform you of:

• Personal Information we may collect from you when you visit this Platform or when you avail yourself of the services provided on this Platform,
• how we use and secure such Personal Information,
• The choices you have regarding our use of your personal information,
• Your ability to review, correct and object to the use of such Personal Information, in accordance with the Nigeria Data Protection Regulations, 2019, its subsequent amendments and other regulations regulating the collection and processing of personal data in Nigeria.
• Access (if any) of third parties to personal data and purpose of access.
• Available remedies in the event of violation of the privacy policy

Please read this Privacy Notice (the “Notice”) to understand our policies, processes, and procedures regarding the processing of your personal data. Please note that the application of this Notice does not extend to services that are not owned or controlled by Xaron, including third-party websites and the services of other Xaron’s partners. Xaron ensures to handle personal data provided to us by our customers and merchants (“Users”) in strict compliance with applicable data privacy and protection laws.

The Information we Collect

When you visit Xaron’s website, we do not collect your Personal Information unless that which you reveal to us voluntarily. You may therefore access our webpage anonymously unless you voluntarily tell us who you are. Notwithstanding, when you visit our web Platform, our Web server automatically recognizes only the customer’s domain name, but not the e-mail address (where possible), we may then proceed to track this Internet Domain Address for the purpose of data analysis to identify trends and statistics.

However, to access the Xaron Services and for optimal use of this application/website, we collect Personally Identifiable Information which you voluntarily provide to us. Hence, there may be times, such as when you subscribe to any of the services rendered on the Platform, register to receive marketing information, or to participate in competitions, undertake user reviews/ratings, contests or promotions, etc, at which we ask you to provide certain information about yourself such as your name, address, mobile number, email address, birth date, gender, occupation, personal interests and other ancillary information relating to your person. The decision to provide such information is completely your own choice but if you choose not to provide this information we request, you will be unable to take advantage of our offerings and will not be granted access to the Services we render on the Platform.

Personally identifiable information includes the following:

• Sign-up information:When you register to use the services offered on our platform, we will collect Personal Data that is necessary to on-board you such as your name, email address, and mobile phone number. We may require you to provide additional personal details as you use our services.

• Information from other sources :We may collect information from other sources, such as our social media platforms when you reach out to us to lodge a complaint about our services. However, we will only ask for information required to help us be of service to you.

• Other information we collect related to your use of our website or Services:We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

• When you apply for a job with us:We may request Personal Data about your education, employment and state of health. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and any monitoring activities which may be required of us under applicable laws as an employer.

• Other personal identifiable details include but not limited to (e.g. email address, password, name, address, telephone number, business name, camera sensor data, bank details, and other unique identifiers including but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others). For ease of transacting, we may also collect your contact details, only if your permission to do so is granted.

• We may also carry out screening checks (including reference, background and criminal record checks).

• We may exchange your Personal Data with law enforcement agencies, referees and your previous employers.

• Without your Personal Data, we may not be able to process your application for positions with us.

• We also collect non-personally identifiable information including but not limited to dynamic IP address, geolocation data, screen size and cookies data. We use Technological methods to collect and store personal information such as cookies, JWT, web beacons etc. We will not share or disclose this information with third parties except as a necessary part of providing our users with access to our website and services. By visiting and using our website, you agree to our use of cookies in line with Xaron’s policies. For more details about Cookies, please read our Cookies Policy available through this link.

• We do not collect the information of minors.

• If you are under the age of 18, you are not eligible to use the service offered on our digital platform. Kindly refer to our Terms.

• Uses of Information

• Provide our services:You agree that Xaron is simply a marketplace for all your logistics needs that are duly serviced by affiliated dispatch riders. Hence, the information you provide to us on our Platform, including your Device Identifiers and Personal Information, Business Information and Usage Information, will be shared with our affiliates for the purpose of rendering the desired services.

  If at any time you wish to unsubscribe to our contact list/mailing system or promotional advertisement, please let us know by sending us an email at Admin@xaron-tech.com or writing to us at Admin@xaron-tech.com Attention: Customer Service

• Customise, measure and improve our services:From time to time, we may provide your Personal Information to our customer service agencies or customer service unit, for research and analysis purposes so that we can monitor and improve the Platform, online experience and our services to you. We may contact you by post, email, telephone or through any of the social media platforms, to ask you for your feedback and comments on our services. We also use your Personal Information to customise and improve your experience on our Platform by serving you specific content or ads that are relevant or personalized to you. To this end, you agree that we may also provide you with information about other services we offer which you may not have signed up for or which may not be available at the time of your onboarding. We however undertake that we will not send unsolicited marketing communications to you by SMS or email if you have not opted in to receive them.

  Therefore, by continuing the use of our platform, you agree that we may Market Xaron and/or our partner’s products and services to you. You also agree that we may use cookies to provide a targeted display, feature, service or offer to you.

• Communicate with you about your account:The information we collect are also used to communicate with you about your account or transactions with us and send you information or request feedback about features on our website and applications or changes to our policies. The information we obtain are also useful in aiding investigations and attending to your complaints or enquiries within reasonable time.

• Comply with Legal Obligations:Your data will also be used to comply with our obligations and deriving from the terms of use, as well as all applicable laws and regulations. To this end, you accept that Xaron shall have the right to monitor your account usage and if required, will disclose personal information to local enforcement or investigative agencies or any competent regulatory or governmental agencies to assist in the prevention, detection or prosecution of fraud or criminal activities.

• In addition to the above, we also use your Personal Identifiable Information to:
  • process your requests, resolve disputes and troubleshoot problems;
  • prevent potentially prohibited or illegal activities and enforce our Terms;
  • compare information for accuracy and verify with third parties;
  • update our databases and provide user support;
  • Manage risk, fraud and abuse of our services and you from fraud by verifying your identity.
  • Trail information breach and rectify such identified breaches.

• What Constitutes your Consent?

  • You accept this privacy policy when you give consent upon access to our platforms, use the services offered on our website and digital platform or visit any of our offices for official or non-official purposes.
  • By submitting your information on this Platform, you consent to the use of that information as set out in this Data Protection Privacy Policy. If we change our Data Protection Privacy Policy, we will post the changes on the Platform and send you an email notifying you of the change, so that you may be immediately aware.
  • You agree that you do not object to us or our Service Providers, contacting you for statistical or survey purposes, to improve this Platform and its services to you. You consent to such contact whether by telephone, email or in writing.

• Third Party access to Personal Information

  • By submitting your information on this Platform, you consent to the use of that information as set out in this Data Protection Privacy Policy. If we change our Data Protection Privacy Policy, we will post the changes on the Platform and send you an email notifying you of the change, so that you may be immediately aware.
  • You agree that you do not object to us or our Service Providers, contacting you for statistical or survey purposes, to improve this Platform and its services to you. You consent to such contact whether by telephone, email or in writing.
  • Xaron assures you that it shall only obtain your data with your consent and that your data shall only be used for the purpose for which it was obtained. However, we may share your Personal Data with companies with companies affiliated to Xaron, as well as third party service providers engaged by us to provide services to Xaron subject to appropriate data security and protection. In addition, we may transfer your Personal Data out of Nigeria in line with the requirements of the Nigeria Data Protection Regulation, 2019. However, Xaron does not share your personal information with unauthorised persons and adequate safeguards have been put in place to prevent unauthorised access and to ensure confidentiality of your personal information.
  • If all or part of our business is sold, (whether by sale of shares or assets) or integrated with another business, your details and Personal Information may be disclosed to our adviser and any prospective purchaser or purchasers and their advisers and will be passed on to the new owners of the business. We’ll notify you (via a message to the email address associated with your account) of any such deal and outline your choices in that event.
  • Following completion of any such sale or transfer, your Personal Information shall be disclosed and transferred to such new owner or third party.
  • Our website may contain third-party links or links to other websites. Please be advised that we are not responsible for the privacy practises or contents of these sites and shall not be responsible for your use of such websites. We encourage our users to be aware of when they leave our website and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site before disclosing any personal information to them. Xaron will not accept any responsibility for any loss or damage in whatever manner resulting from your disclosure of your personal information to third parties.
  • In addition to the above, we may share your Personal Data or other information about you with others for the following reasons:
  • With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf.
  • With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Xaron’s business purposes or as permitted or required by law, including:
    • In compliance with a law, legal process or regulations;
    • To law enforcement authorities or other government officials,
    • or other third parties pursuant to a court order or other legal process or requirement applicable to Xaron’s or Xaron’s corporate family;
    • where disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
    • To protect the vital interests of a person.
    • To investigate violations of or enforce our term or other legal terms applicable to any service;
    • To protect our property, services and legal rights;
    • To facilitate a purchase or sale of all or part of Xaron’s business
    • To companies that we plan to merge with or be acquired by; and
    • To support our audit, compliance, and corporate governance functions.
  • You understand that we may also share your Personal Data and other information with your consent or direction.

• Your Rights as Data Subjects

  You can exercise the following rights with respect to your Personal Data with Xaron:

  • request and access your Personal Data collected and stored by Xaron;

  • withdraw consent at any time. For example, you can withdraw your consent to receive our marketing or promotional materials or unsubscribe to our newsletters;

  • object to automated decision making;

  • request rectification and modification of Personal Data kept by Xaron;

  • request for deletion of your Personal Data;

  • be informed of and entitled to provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data were collected;

  • request that Xaron restricts processing of your Personal Data; and

  • request for information regarding any specific processing of your personal data.

• You may exercise any of these rights by sending an email to Admin@xaron-tech.com where your requests will be treated promptly.

• We will only use your Personal Data if we have a proper reason for doing so. The Nigeria Data Protection Regulation (NDPR) sets out the lawful basis for data processing as follows. This include:

• To comply with our legal and regulatory obligations.

• To perform a contract with you or to take steps at your request before entering into a contract.

• To use your Personal Data as is necessary for our legitimate interests or the legitimate interests of others.

• To protect your interest, the interest of another Data Subject or for the performance of a task carried out in the public interest or in exercise of official public mandate vested in us.

• Xaron Employee Obligation

  Xaron employees who handle personal information are under an obligation to treat it confidentially and may not disclose it to third parties. Xaron employees are also responsible for the internal security of the information. Employees who violate Xaron's privacy policies are subject to the company’s disciplinary procedures.

• Correspondence

  Should you send us correspondence including chats, calls, emails and letters, we will retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Xaron to you. The rationale for this retention is to keep records of our relationship, measure and improve customer service and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

• Security

  • Xaron is committed to managing customer information with the highest standards of information security. We protect your personal information using physical, Technologynical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. To prevent unauthorised access or disclosure of Information we have physical, electronic and managerial procedures in place to keep your information safe. Once logged into your Xaron account, all internet communication is secured using Transport Layer Security (TLS) Technologynology and the connection is encrypted and authenticated using AES 128bit encryption key and uses Elliptic Curve Diffie-hellman key exchange (ECDHE) RSA as a key exchange mechanism and only authorised access to personal information is granted only to employees who require it to fulfil their job responsibilities.

  • The security of your Xaron prepaid account also rests on the protection of your PIN. You should not share your PIN with anyone and no employee of Xaron will ever ask you for either of these so any email or correspondence requesting for such information should be treated as unauthorised and suspicious and forwarded to Admin@xaron-tech.com. We will endeavour to respond to such emails as soon as possible.

  • Should you share your PIN with any third parties, such third parties will have access to your account and your personal information, and you may be responsible for any actions taken using this information. Xaron shall not be liable or responsible for any breach or loss arising from the disclosure of your PIN or other private information to any third parties. In the event you suspect a third party has gained access to your PIN, please log into your Xaron profile, change it and notify us straightaway.

  • Although we make good faith efforts to store Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Information. If we become aware that your Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

• Retention of your personal data

  • Xaron takes appropriate measures to ensure that your Personal Data is only processed and retained for a period in line with the purposes set out in this Notice, as is stated under our Terms and Conditions or as required by applicable laws, until a time it is no longer required or has no use. We will also determine what action is to be carried out after the period stated in policies expired.

  • The security of your Xaron prepaid account also rests on the protection of your PIN. You should not share your PIN with anyone and no employee of Xaron will ever ask you for either of these so any email or correspondence requesting for such information should be treated as unauthorised and suspicious and forwarded to Admin@xaron-tech.com. We will endeavour to respond to such emails as soon as possible.

1.18 Inquiries

Xaron is responsible for ensuring that our day-to-day procedures are aligned with this Privacy Policy. Should you have any questions about this privacy statement, Xaron's information services or your transactions on Xaron, you can contact us via our customer helplines or by email to Admin@xaron-tech.com