Privacy & Cookie Policies
Last updated: 19 June 2016
When using our services or providing us with your personal information, you accept this Policy. This Policy may be amended at any time by posting a revised version on our website.
In this Policy, “personal information” has the meaning set out in applicable privacy legislation. Essentially, personal information is information or an opinion about an individual who is reasonably identifiable.
1. Information We Collect
1.1. We may obtain information about you in a variety of ways. When you visit the Nje-Njel website or use our online services, we collect information sent to us by your computer, mobile phone or other access device. We may obtain information from you in our role as a processor of payment transactions, or we may have a direct relationship with you and in the context of that relationship you may choose to provide personal information to us.
1.2. The information sent to us automatically includes your computer IP address, the pages you access, device identifiers, the type of operating system you are using, standard web log data, data associated with cookies and other information. Web log data includes the browser type you’re using and traffic to and from our site.
1.3. In addition to this information, in the event that you use our services and engage in making a payment transaction through Nje-Njel we may collect the following types of information:
1.3.1. contact information (such as name, physical address, phone number or e-mail);
1.3.2. more detailed personal information, such as your date of birth;
1.3.3. financial information, such as bank account numbers, names and routing codes (we do not directly handle credit card data);
1.3.4 logs of our chat or other communication with you.
1.4. In the course of processing your payment transaction we work with payment collection and banking partners. In doing so, a partner or bank may share with us information about the originating account such as account name, number, routing code and other identifying information to provide us with notification that a payment has been received.
2. How We Use The Information We Collect
2.1. We may use the information we obtain about you to:
2.1.1. process your payment transaction and keep you informed about the status of your payment;
2.1.2. comply with and enforce applicable legal requirements, industry standards and our policies;
2.1.4. respond to your inquiries, resolve disputes and provide support;
2.1.5. analyse, operate and improve our business (including enhancing our user experience, managing communication and functionality and developing new products and services);
2.1.6. inform you of services we provide through targeted marketing messages, service updates and promotional offers based on your communication preferences; and,
2.1.7. compare information for accuracy and verify it with third parties.
2.2. Further our business relationship with you, if we have collected your personal information in the context of an actual or potential business relationship.
2.3. Fulfil other purposes to which you have consented, which would be reasonably expected by you or which are otherwise authorised or required by law.
3. Information We Share
We may share your information in the following ways:
3.1. we may share your information with service providers who assist us with our business. For example, to process your payment to an educational institution, we may share some of your personal information with the institution;
3.2. In some cases, in order to execute the successful processing of your payment, we may share bank/payment receipt documents that you have sent to us with service providers or banking partners under contract whom we work with to assist with the reconciliation of that payment. Our contracts dictate that these service providers only use your information in connection with the services they provide to us and not for their own benefit;
3.3. we may share personal information with business associates, partners and affiliates as we see fit;
3.4. if we are required to do so by law or legal process or to comply with the law, or when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity or to investigate breaches of our Website Terms of Us and other agreements;
3.5. on our website, you may choose to use certain features which are provided by other entities. These features, which include social networking buttons (which will be prominently displayed on our webpage), are operated by third parties that are not affiliated with Nje-Njel, and they may collect information directly from you. These third parties may use any personal information that you provide to them in accordance with their own privacy policies and practices. Nje-Njel strongly suggests you review the third parties’ privacy policies before interacting with them.
4. Rights and Choices
You may have certain rights regarding the personal information we collect and maintain about you and how we communicate with you.
4.1. when we request information from you on our site, you may always choose not to provide us with that information. However, if you decline to provide us with certain information, we may not be able to provide you with the services offered;
4.2. you may opt-out of e-mail marketing communications by clicking on the unsubscribe link within marketing e-mails you receive from us or by contacting us;
4.3. if you are located in the European Economic Area or Switzerland, you may direct us not to share your personal information with third parties, except:
4.3.1. with service providers under contract we have retained to perform services on our behalf;
4.3.2. in the event we are acquired or we transfer all or a portion of our business or assets;
4.3.3. if a legal process or law requires disclosure;
4.3.4. at the request of law enforcement authorities; or,
4.3.5. when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity;
4.4. where required by law, Nje-Njel obtains your prior opt-in consent at the time of collection for the processing of:
4.4.1. personal information for marketing purposes; and,
4.4.2. personal information deemed sensitive pursuant to applicable law;
4.5. subject to applicable law, you may have the right to request access to and receive information about the personal information we hold about you, update and correct inaccuracies in your personal information, and have the information deleted, as appropriate. To request to exercise this right, contact us as described below. Your right to access, update, correct or delete personal information may be limited in some circumstances by local law requirements.
5. Data Transfer
5.1. Nje-Njel may store, process and/or transfer your personal information in or to countries other than the country in which the information was originally collected, such as the United States (‘U.S.’). For example, we may disclose personal information to our overseas related companies, overseas service providers and to overseas educational institutions in order to process your payment.
5.2. The countries in which these overseas parties are located will depend on the circumstances. In the ordinary course of business we commonly disclose personal information to parties located in the U.S, UK, Australia and the European Union.
5.3. By using Nje-Njel services or otherwise providing us with your personal information, you consent to our transferring of your information to countries outside your home country, including the U.S. We will protect your information as described in this Policy.
5.4. We comply with the applicable legal requirements providing adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland.
6. How We Protect Your Personal Information
6.1. Nje-Njel maintains appropriate safeguards combining technical and physical measures to provide protection to the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, interference, modification, disclosure or misuse.
6.2. We limit access to information you provide us to those employees and workers who we believe reasonably need that information in order to do their jobs.
6.3. We continue to assess new technology for protection of information and upgrade our information security systems where appropriate.
7. Links to Other Websites
8. Changes to this Policy
Nje-Njel may amend this Policy periodically and without prior notice to you (by posting an updated version to our site) to reflect any changes in our information practices. We will indicate at the top of this Policy when it was most recently updated.
9. Questions, Comments and Complaints about Our Handling of your Personal Information
9.1. If you have any questions, comments or complaints about our collection, use, storage or disclosure of personal information, or if you believe that we have not complied with this Policy or our obligations under applicable privacy laws, please contact us using our contact details given below.
9.2. When contacting us please provide as much detail as possible in relation to your question, comment or complaint.
9.3. Nje-Njel will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
10. Contact Information
If you have any questions or concerns related to this Policy, or if you wish to request access to, or correction of, your personal information or make a privacy complaint you may contact us by clicking here or by writing to us at:
20-22 Wenlock Road, N1 7GU, London, United Kingdom, or by e-mailing us at firstname.lastname@example.org
11. Jurisdiction and applicable law
11.1. Subject to clause 11.3 below, in matters of contract the courts of England & Wales will have exclusive jurisdiction over any claim arising from, or related to, a visit to our site although we retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country.
11.2. This Policy and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with English law.
11.3. Notwithstanding clause 11.1 above, Nje-Njel shall have the option, in its absolute discretion, to require that you and Nje-Njel submit to binding arbitration for the purpose of resolving any dispute or controversy that shall arise in relation to this Policy or your use of this site, though he exercise of this option shall not prejudice your statutory rights.
11.4. The option in clause 11.3 above shall be exercised on reasonable written notice to you, in which case the dispute or controversy shall be finally settled under the Rules of Arbitration of the International Chamber of Commerce by one or more arbitrators appointed in accordance with the said Rules, and the decision of the arbitrators shall be final and binding, save in the case of manifest error.