Privacy Policy
Release Date: 15th of November 2020
Version: 0.2
In this privacy policy, we, Ultima Limited (“Ultima”), explain how we collect and use your personal data in relation to the production, broadcast and all personal data processed by Ultima if you apply to participate in any of our productions, media projects or use any of our broadcasting channels (radio and television), our websites, platforms, mobile applications, ‘contact us’, or use our social media platforms (together “our Platforms”). We process your personal data primarily for your participation in our productions and media projects but we may also use your data to send you advertisements and offers tailored to your interests and preferences (together “our Services”). In this privacy policy, we provide more information about the personal data we collect and use and what your rights are. More importantly, this policy tells you:
a. What information we might collect about you.
b. How we might use that information.
c. When we might use your details to contact you.
d. What information of yours we might share with others.
e. Your choices about the personal information you give us.
- Who we are?
Ultima is a company incorporated under the laws of the Federal Republic of Nigeria with its registered office at Ultima Studios, 1 Ultima Studios Street, off Amore Street, Lekki Phase1, Lagos State, Nigeria.
Ultima is a world class media and production company engaged in the business of designing and undertaking production and media projects. Ultima is the owner of the broadcasting radio station known as 88.5 UFM.
2. Types of personal data we process
2.1 General
We may collect and process the following categories of personal data:
2.1.1 Name and Contact details
When you use our Platforms, we may record your name, contact details, gender and date of birth. Your contact details may include your address, telephone number and e-mail address. When you create an account on our Platforms, we may also record your sign-in details and the information you fill out on the account.
2.1.2. Our communication with you
When you send us an e-mail or chat with us online or through social media, we register your communication with us as well as your contact information such as email address when you email us or social media handle when you mention us in a post (for example, we collect your Twitter handle when you mention or tag us on Twitter). We also register your communication preferences, for example when you subscribe to one of our newsletters. When you call us, our customer support will register your questions or complaints in our database. We may also record telephone calls for training purposes or to prevent or combat fraud.
2.1.3. Information we collect when you use our Platforms
When you visit our website, we may register your IP address, browser type, operating system, referring website, web-browsing behavior and app use.
We also collect information through cookies and similar technologies when you visit our website. For more information please read our Cookie Policy. If you visit our website through a link in an e-mail or when you are logged into an account created on our Platforms, we may link the information we collect through cookies and similar technologies to other data we process about you.
We receive an automatic notification when you open our e-mails or click on a link in such e-mails. We may combine this information with other data we process about you. With your permission, we may also receive your location data.
You can also agree to provide us with access to certain data stored on your mobile phone (such as photos and contacts).
2.1.4 Information in relation to social media
Depending on your social network settings, we may receive information from your social network provider. For example, when you sign into your account on our Platform, using a social network account, we may receive your social network profile including your contact details, interests and contacts. For more information on the personal data that we receive from your social network provider and how to change your settings, please check the website and privacy policy of your social network provider.
2.1.5 Information you choose to share with us
You may choose to share information with us, for example when you share your interests and preferences with us, leave a comment on our social media pages, fill out a customer survey or submit an entry for a contest in any of our productions.
2.2 Children younger than 16
2.2.1 Why we collect your information
Ultima’s production and media projects are generally family friendly. Nonetheless, we keep your information so that we get the right services for you, plan and improve our Services and keep in touch with you.
We will always tell you why we are collecting your information and if we need your parent or guardian’s permission, we will give you clear details about what is needed at the time.
2.2.2 We may ask for your age
To make sure you are suitable to use Ultima’s Platforms, we may ask for your age and where applicable, we will ask you to obtain your parent or guardian’s consent to use our Platforms. Where we require you to obtain your parent or guardian’s consent, you will receive a notification.
2.2.3 Contacting your parent or guardian
We may ask your parent or guardian for additional details so that we can contact them.
Sometimes, we will also tell your parent or guardian about your activity. For example, when you apply to participate in any of our production or media projects, we might contact your parent.
2.3. Specific services, mobile apps, events, contests or campaigns
For specific services, mobile apps, events, contests or campaigns, we may collect other types of data than those described in this privacy policy. We will inform you about this when you register for the service, event, contest, or campaign, or when you download the app.
3. How we collect your data
We collect the categories of personal data referred to above in the following ways:
3.1 Personal data provided by you
For example, when you register to use our Platforms or to participate in any of our productions contact our customer support, subscribe to receive our e-mails, fill out a customer survey, register for one of our events or participate in a promotional contest.
3.2 Personal data received from partners or sponsors to participate in our productions
See ‘Who we are’ in 1 above. Some of our productions and media projects are offered in collaboration with sponsors, facilitators, partners, licensors, contributors, broadcasting platforms and other third parties (“our Partners”). Where for any reason, you provided or shared data with our Partners to participate in any of our production or media projects, our Partners will share such data with us and we will receive such data to enable you participate in the required production or media project. You can find more information on how our Partners handle your personal data in their respective privacy policies. However, we do not share your data with Partners except as provided in 4 and 5 below.
3.3 Personal data received from social media networks
If you use social networks, we may also receive information from your social network provider in the manner explained in 2.1.4 above.
4. Purposes for which we use your personal data
4.1 General
The main purposes for which we use your personal data are:
4.1.1 Participation in our production and media projects
We process your data under 2.1.1 and 2.1.2 to enable you participate in our production and media projects and to contact you, where necessary, in respect of any of our production or media project you have participated in or when we have a new production or media project similar to that which you have indicated interest.
4.1.2 To provide you with a seamless digital experience on our Platforms
With reference to 2.1.3, to offer you the best possible digital experience on our Platforms, we may:
a. analyse your use of our website or apps, so that we can tailor our communication towards the digital channel or device that you use most.
b. some of our digital services may use your location, for example, to show you the nearest location of interest.
4.1.3 For statistical research
a. General: We research general trends on our Platforms, and trends in the behavior and preferences of our users. We use our research results to improve our Platforms and projects, develop better services and offers for you and our Partners, provide better customer service, and improve the design and content of our Platforms.
b. Categories of data: To perform our research, we may use the categories of data described at 2.1. However, we only use ‘aggregated data’ or ‘pseudonymised data’ for our research. This is data that cannot be traced back directly to you because all directly identifiable elements (e.g. names and e-mail addresses) are removed or encoded and given a number. We take appropriate measures to ensure that only a limited group of employees have access to the analysis.
c. Legal basis and right to object: We process your personal data for our legitimate interests described in 4.1.3(a) above. You have the right to object, on grounds relating to your situation, at any time to the processing of your personal data for statistical research in the manner explained in 8 ‘Your rights’ below.
4.1.4 For marketing purposes
- General: If you participate in any of our production or media projects or sign up on any of our Platforms, we will send you updates about our production and media projects as well as our offers and services.
b. Types of communication
E-mails: If you subscribe to our project or Platform updates or offers and marketing, we will send you email updates about our production and media projects as well as your use of our Platforms and offers tailored to your interests and preferences.
Direct messages through other communication channels: We may use other communication channels to send you direct messages with personalised advertisements and special offers, with your consent, mobile push notifications or social channels (e.g. Messenger, WhatsApp, or WeChat etc).
Display relevant information and personalised advertisements on websites: please see our cookie statement. We may also use your personal data to exclude you from advertisements which are no longer relevant for you.
c. Personalised advertisements and offers: We aim to make advertisements and offers as relevant as possible for you. To that end, we may use and combine the categories of personal data described at 2.1 and 4.1.3. For example, in our e-mails, we may include information on new production and media project(s) similar to those in which you have indicated interest.
We may also show you targeted advertising through other companies’ site like Google, Facebook, and Twitter for example. This could be showing you an Ultima’s sponsored message where we know you use Ultma’s Platforms. If you do not wish to see our targeted advertising, you can set your preferences in your social media companies’ settings.
d. Legal basis and right to object
We send you information or updates based on your consent. We personalise your advertisements and offers on the basis of our legitimate interest and the interests of third parties so as to send you relevant updates and offers. You have the right to object to the use of your personal data for direct marketing purposes at any time as described in 8 ‘Your rights’ below.
f. Unsubscribe
You may unsubscribe from communication emails at any time by clicking on the unsubscribe link in the e-mail. You will then unsubscribe from that email update. If you would like to unsubscribe from all types of Platform updates, you can change your communication preferences in the account(s) you have created on our Platforms. In that case, you will only receive e-mails necessary to be able to participate in our production and media projects (e.g. request to update your password). You may also unsubscribe by contacting us. To unsubscribe from emails from our Partners (where applicable), please see privacy policies of our Partners.
4.1.5 To communicate with you
We use your contact details to communicate with you about your participation in our production and media projects, to answer your questions, or to address your complaints.
To update you on changes to Ultima’s policies, practices, and our Terms of Use.
To check with you about any other services you have signed up for. This will include telling you about inactivity on any account you have created on any of our Platforms.
To answer you when you have contacted us or to respond to a comment or complaint and to invite you to take part in surveys about Ultima’s projects or services, which are always voluntary.
We will only contact you when we need to, or when you have given us permission. We will never contact you to ask for your passwords including that of any account you have created on our Platform(s).
4.1.6 To conduct our business operations or to comply with statutory obligations
We collect, use, and retain your personal data to manage your participation in our production and media projects, such as for record-keeping purposes, to prevent misrepresentation, to prevent or combat fraud, or to settle disputes. In the case of misrepresentation, fraud or misuse of our Platforms, we may enter your personal data in our internal fraud control and warning systems. As a result, your participation in any of our production or media projects may be subject to close scrutiny and, in particular cases, may be refused or cancelled or you may no longer be welcome to participate in any of our production or media projects or only be allowed to participate on certain conditions. We also process your personal data to comply with our legal and tax obligations.
4.1.7 When you use another company’s service to connect to us
When you are required to sign in to an account you have created on our Platform and use a separate company such as voice-enabled devices (e.g Amazon’s Alexa) to connect to us, we will share an identifier for your account on our Platform with the company who runs the service you are using. Please endeavor to check such company’ privacy policy so that you know how your information will be used. Ultima will not be responsible where you use or access our Platforms using another company’s service.
4.2. Specific services, apps, events, contests, or campaigns
For specific services, apps, events, contests, or campaigns, we may use your personal data for purposes other than those described in this privacy policy. We will inform you about those purposes when you register for the service, event, contest, or campaign, or when you download the relevant app.
4.3. Legal basis
We may process your personal data only if we have a legal basis for doing so. In many cases, we need your personal data to manage your ‘participation in our production and media projects’ (4.1.1). In those cases, the legal basis for processing your data is ‘necessary for the performance of a contract’. If you have consented to a processing activity (which consent you may withdraw at any time), we will process your data based on that consent. In certain cases, we may use your personal data if we or third parties have a legitimate interest in doing so. We will always consider all interests carefully. Based on that legal basis, we will process your data for instance, combatting fraud, statistical research, or personalising offers and advertising. We may also have a legal obligation to process your data, for example for tax reasons. If you refuse to provide the personal data we need to perform the contract we have concluded with you or to comply with a legal obligation, we may not be able to allow you participate in our production and media projects or provide all the services you have requested from us.
5. Granting access to or sharing data with third parties
5.1. General
We may share your personal data with third parties in the following cases but we will never sell your data:
5.1.1 Our Partners Obligations: To enable our Partners fulfil their obligations in relation to our production and media projects.
5.1.2 For support or additional services: To execute our production and media projects, we use support or additional services of third parties, such as productions teams, broadcasting stations, IT suppliers, social media providers, marketing agencies, medical teams and screening service providers. All such third parties are required to adequately safeguard your personal data and only process them in accordance with our instructions.
5.2. Specific services, apps, events, contests, or campaigns
For specific services, apps, events, contests, or campaigns, we may share your data with third parties other than those described in this Privacy Policy, for example, when we organise a campaign or an event in collaboration with a Partner. We will inform you about this when you register for the service, event, contest, or campaign, or when you download the app.
5.3. Third-party websites
Our website contain links to third-party websites. If you follow those links, you will leave our website. This privacy policy does not apply to the websites of third parties. For more information on how they handle your personal data, please check their privacy or cookie policies (if available).
6. Security and retention
6.1 Security
6.1.1 Our commitment: Ensuring the security and confidentiality of your personal data is our priority. Taking into account the nature of your personal data and the risk of processing, we have put in place all appropriate technical and organisational measures as required by applicable legal provisions in particular (s2.6 of the Nigerian Data Protection Regulation (NDPR) and Article 32 of the General Data Protection Regulation (GDPR)) so as to ensure an appropriate level of security and, in particular, to prevent any accidental or unlawful destruction, loss, alteration, disclosure, intrusion of or unauthorised access to these data
6.1.2 The security measures we have taken
a. Organisational measures: We have implemented and maintained various organisational measures intended to strengthen the awareness and accountability of our employees. We have programmes in place designed both to ensure awareness and to promote the sharing of good practices and safety standards. In this context, a rich collection of documents on information security challenges and privacy protection have been made available to employees.
- Technical measures: We strictly control physical and logical access to internal servers hosting or processing your personal data. We protect our network with state-of-the-art hardware devices (Firewall, IDS, DLP etc.) as well as architectures (including secure protocols like TLS 1.2) in order to prevent and limit the risk of cybercrime.
- The evolution of our security systems: To maintain an appropriate level of security, we have internal processes in place based on the best standards (in particular, the ISO 27000 family of standards). We rely on dedicated experts to guarantee the best possible level of protection.
- How to protect yourself: The personal data security and confidentiality data depends on everyone’s best practices. We advise you not to disclose the passwords you use to access our Platforms or services to third parties, to log out of your profile and social account systematically (especially in the case of linked accounts), and to close the browser window at the end of your session, especially if you are accessing the Internet from a public computer. This will prevent other users from accessing your personal data. To avoid the risk of hacking, we recommend using different passwords for every online service you use. We cannot be held responsible for theft of your data on a platform which is not managed by us. In addition, we strongly recommend that you do not distribute to third parties, any document issued by Ultima containing your personal data or other information related to your participation in any of our production or media projects or use of our Platforms or to publish these on social networks. If you decide to publish these documents on social media, you are responsible for consulting and understanding the general conditions of use, information security practices and privacy policies applicable to these third-party social networks. We cannot be held responsible for how data is processed, stored or disclosed on these platforms. To find out more about our measures with regard IT security, please consult Ultima’s IT security portal. Human beings and not robots will make the big decisions that affect you.
6.1.5 Management of security incidents: There is no such thing as ‘zero risk’ and even if we implement all the security measures recognised as appropriate, unforeseen things can happen. We have specific procedures and resources in place to manage security incidents under the best possible conditions. We have also set up a specific procedure for assessing possible breaches of security that could lead to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to your personal data, for notifying the competent supervisory authority within the period provided for by applicable law, and for warning you when a breach is likely to result in a high risk to your rights and freedoms. Tests are carried out periodically to verify the functioning of the security installations and adequacy of the procedures and devices deployed.
6.2. Retention
We do not keep your personal data for any longer than is necessary. How long your personal data is retained depends on the purposes for which the data is processed and the applicable statutory retention periods.
7. International transfer of data
7.1 Ordinarily we do not transfer your data outside Nigeria. However, please note that some companies who provide data storage services to us run their services from outside the Federal Republic of Nigeria. We nonetheless only let that happen if we are satisfied with their levels of security. Keep in mind that when you give us personal information, it may be transferred or stored in a location outside the Federal Republic of Nigeria.
You may not be able to access some of our production and media projects outside Nigeria, where such production and media projects are licensed for exclusive production in Nigeria.
8. Your rights
8.1 Contact us to exercise your rights: You may contact Ultima (please see 8.4 below) to exercise any of the rights you are granted under applicable data protection laws. These rights include:
8.1.1 The right to access your data: You may ask us whether we process any of your personal data and, if so, to receive access to that data in the form of a copy.
8.1.2 The right to rectify your data: You have the right to have your data rectified if it is inaccurate or incomplete. Upon request, we will correct inaccurate personal data about you and, considering the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.
8.1.3 The right to erase your data: You have the right to have your personal data erased. This means that we will delete your data. Erasure of your personal data only takes place in certain cases, as prescribed by law and listed in s12.13.8 of the NDPR and Article 17 of the GDPR. This includes situations where your personal data is no longer necessary in relation to the purposes for which it was originally processed, and situations where the data was processed unlawfully. Due to the way in which we maintain certain services, it may take some time before backup copies are erased.
8.1.4 The right to restrict the processing of your data: You have the right to obtain a restriction on the processing of your personal data. This means that we will suspend the processing of your data for a certain period. Circumstances which may give rise to this right include situations where the accuracy of your personal data is contested, and we need some time to verify its (in)accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted.
8.1.5 The right to data portability: Your right to data portability entails that you may ask us to provide you with your personal data in a structured, commonly used and machine-readable format, and have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.
8.1.6 The right to object to processing: You have the right to object to the processing of your personal data. This means that you may ask us to no longer process your personal data. This only applies if the ‘legitimate interests’ ground (including profiling) constitutes the legal basis for processing. You can object to direct marketing at any time and at no cost to you if your personal data is processed for this purpose, which includes profiling to the extent that it is related to direct marketing. If you exercise this right, we will no longer process your personal data for such purposes.
8.2. Withdrawal of consent
You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent. For example, you can withdraw consent by clicking the unsubscribe link in the e-mail or adjusting your communication preferences in your account created on any of our Platform. You can also contact Ultima. For more information on how you can withdraw your consent for cookies and similar technologies we use when you use our website, please check our cookie policy.
8.3. Denial or restriction of rights
There may be situations where we are entitled to deny or restrict your rights as described in 8.2 above. In all cases, we will carefully assess whether such an exemption applies and inform you accordingly. We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals, or refuse to delete your personal data if the processing of such data is necessary for compliance with legal obligations. The right to data portability, for example, does not apply if the personal data was not provided by you or if we process the data on grounds other than your consent or for the performance of a contract.
8.4 Ultima’s Privacy Office
If you wish to exercise your rights, all you have to do is send a request to:
Addressee: Data Protection Officer, Ultima Limited
Ultima’s office address: Ultima Studios, 1 Ultima Studios Street, off Amore Street, Lekki Phase1, Lagos, Nigeria.
Post Code: 105102
E-mail: data.protection@ultima.ng
8.5 Questions, comments or complaints
If you have any questions, comments, or complaints, please feel free to contact us. If your concerns have not been addressed to your satisfaction, you have the right to file a complaint with the competent supervisory authority.
9. How this privacy policy is updated
This privacy policy took effect on 15th November 2020. It is amended from time to time. We will notify you of any changes before they take effect.
© Ultima Limited, 2020
