Privacy Policy

I. Introduction  /  II. Overview  /  III. Data collections and uses  /  IV. Choice and transparency  /  V. Updates to this notice

I. Introduction

When you use Anya, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

Last modified: March 10, 2024

Effective date: April 6, 2024

II. Overview

1. Scope

This notice applies to users of Anya’s services anywhere within Nigeria and Africa at large and the countries in which we operate, including users of Anya’s apps, websites, features, or other services.

This notice describes how Anya and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services within Nigeria and Africa and locations where our app is used unless covered by a separate privacy notice. This notice specifically applies to:

•   Customers: individuals who request and purchase adverts products and services.
•   Media Owners: individuals who provide, or submit their advert rates of products (billboards, lamp poles, OOH and all other inventories)  to Anya, individually or through partner companies.
•   Television Stations: individuals who provide, or submit their advert rates of products and services to Anya.
•   Radio Stations: individuals who provide, or submit their advert rates of products and services to Anya.
•   Newspaper Publications: individuals who provide, or submit their advert rates of products and services to Anya.
•   BRT: Government body that provides, or submits advert rates of to Anya.

This notice also governs Anya’s other collections of personal data in connection with Anya’s services. For example, we may collect the contact information of individuals who use accounts owned by Anya for Business customers or of owners or employees of Anya partners, or we may collect other personal data in connection with our technology and features.

All those subject to this notice are referred to as “users” in this notice.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us through the addresses below with any questions regarding our practices in a particular country or region.

 

B. Data controller and transfer

Anya is the data controller for the personal data collected in connection with the use of Anya’s services anywhere else.

Anya (350-360 Maryland-Ikorodu road, Lagos. Nigeria) is the data controller for the personal data collected in connection with the use of Anya’s services in Nigeria and anywhere our services are used.

III. Data collections and uses

A. The data we collect

Anya collects:

•   Data provided by users to Anya, such as during account creation
•   Data created during use of our services, such as location, app usage, and device data
•   Data from other sources, such as Anya partners and third parties that use Anya APIs or vice-versa

The following data is collected by or on behalf of Anya:

1. Data provided by users. This includes:

•   User profile: We collect data when users create or update their Anya accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes company documents relating to advertising or media ownership, membership or insurance information of the above, user settings. For more information, please see the section titled “How we use personal data.”
•   Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
•   User content: We collect the information users submit when they contact Anya customer support, provide ratings or compliments for other users or ooh partners, radio, tv, digital or otherwise contact Anya. This may include feedback, photographs or other recordings collected by users.

2. Data created during use of our services. This includes:

•   Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, date and time the service was provided, amount charged, and payment method.
•   Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
•   Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

3. Data from other sources. This includes:

•   User feedback, such as ratings, feedback, or compliments.
•   Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
•   Anya account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of Anya for Business accounts.
•   Anya business partners through which users create or access their Anya account, such as payment providers, social media services, or apps or websites that use Anya’s APIs or whose APIs Anya uses.
•   Publicly available sources.
•   Marketing service providers.

Anya may combine the data collected from these sources with other data in its possession.

B. How we use personal data

Anya collects and uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use the data we collect:

•   To enhance the safety and security of our users and services
•   For customer support
•   For research and development
•   To enable communications between users
•   To send marketing and non-marketing communications to users
•   In connection with legal proceedings

Anya does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

Anya uses the data it collects for purposes including:

1. Providing services and features. Anya uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

•   Create and update users’ accounts.
•   Verify advert rates, background history, and eligibility of rates .
•   Offer, process, or facilitate payments for our services.
•   Track and share the progress of deliverables.
•   Enable features that allow users to provide feedback, referrals to Anya.
•   Enable features to personalize users’ Anya accounts, such as creating bookmarks for favorite places and to enable quick access to previous destinations. We may, for example, present Anya Help users with personalization.
•   Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

•   Screening advert rates submitted, physical products and services before enabling their use of our services and at subsequent intervals, including thorough reviews of background checks, where permitted by law, to help prevent the use of our services by illegal individuals.
•   Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
•   Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating media owners with low ratings or who otherwise violated such guidelines across countries of operations.

3. Customer support. Anya uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

•   Direct questions to the appropriate customer support person
•   Investigate and address user concerns
•   Monitor and improve our customer support responses and processes

4. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.
5. Marketing. Anya may use the data we collect to market our services to our users. This includes sending user’s communications about Anya services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by Anya partners. For example, if a user has placed an order, we may provide recommendations, promotions, or ads about similar advert products and or services offered by other Anya partners. Although we may send users communications about Anya partners’ products and services, we do not sell users’ personal data to or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of Anya’s services, and user preferences and settings.

7. Non-marketing communications. Anya may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Anya or its partners.
8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to the use of Anya’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
9. Automated decision-making :We use personal data to make automated decisions relating to the use of our services. This includes:

•   Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Anya, its users, and others. In some cases, such as when a user is determined to be abusing Anya’s referral program, such behavior may result in automatic deactivation.

C. Cookies and third-party technologies

Anya and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Anya uses cookies and similar technologies for purposes such as:

•   Authenticating users
•   Remembering user preferences and settings
•   Determining the popularity of content
•   Delivering and measuring the effectiveness of advertising campaigns
•   Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

 

D. Data sharing and disclosure

Some of Anya’s products, services, and features require that we share data with other users or at a vendor’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Anya may share the data we collect:

1. With other users

This includes sharing:

•   Users’ first name, rating, advert location pickup and/or dropoff locations for physical ads, radio interviews, etc.

•   Delivery recipients’ first name, delivery address, and order information with their delivery partner. We may also share ratings and feedback, or other information to the extent required by law, with the vendor partner and delivery partner depending on the category of product and product type.
•   ·   For those who participate in Anya’s referral program, we share certain personal data of referred users, with the user who referred them, to the extent relevant to determining the referral bonus.

2. At the Vendor’s request

This includes sharing data with:

•   Other people at the user’s request. For example, we share a product ETA and location with a friend when requested by that user, or a user’s advert trip information.
•   Anya business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Anya may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; those with an API or service with which we integrate; or other Anya business partners and their users in connection with promotions, contests, or specialized services.

3. With the general public

Questions or comments from users submitted through public forums such as Anya blogs and Anya social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4. With the Anya account owner

If a user requests or places an order using an account owned by another party, we may share their order or information, including real-time location data, with the owner of that account. This occurs, for example, when:

5. Requests are made from Anya subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

6. With Anya service providers and business partners

Anya provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

•   Payment processors and facilitators
•   Background check and identity verification providers (drivers and delivery partners only)
•   Cloud storage providers
•   Marketing partners and marketing platform providers, including social media advertising services
•   Data analytics providers
•   Research partners, including those performing surveys or research projects in partnership with Anya or on Anya’s behalf
•   Vendors that assist Anya to enhance the safety and security of its apps
•   Consultants, lawyers, accountants, and other professional service providers within the extent that is legally acceptable
•   Fleet partners
•   Insurance and financing partners
•   Airports for shipments

7. For legal reasons or in the event of a dispute

Anya may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Anya’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

 

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With consent

Anya may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

 

E. Data retention and deletion

Anya retains user profile, transaction, and other personal data for as long as a user maintains their Anya account.

Anya may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

Anya retains user profile, transaction, and other information for as long as a user maintains their Anya account. Users may request the deletion of their account at any time through the Settings > Privacy menus in the Anya app. Following such requests, Anya deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Anya retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, Anya may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Anya will delete the account as described above.

Anya may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if Anya deactivates a user’s account because of unsafe behavior or security incidents, Anya may retain certain information about that account to prevent that user from opening a new Anya account in the future.

F. Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Anya’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

1. To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

•   User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their, orders, and accounts; and enable users to make payments or receive earnings.
•   Usage data, which is necessary to maintain, optimize, and enhance Anya’s services, including to determine incentives, connect users and media owners, and calculate costs and earnings.
•   Transaction information
•   Information relating to customer support.

1. For purposes of the legitimate interests of Anya or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent the use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of Anya’s apps.

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Anya’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

1. To fulfill Anya’s legal obligations

For example, Anya is subject to laws and regulations in Nigeria and Africa at large that require it to collect and retain data about our users, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

Anya may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.

1. With consent

Anya may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

IV. Choice and transparency

Anya enables users to access and control the data that Anya collects, including through:

•   In-app settings
•   Device permissions
•   In-app rating pages
•   Marketing opt-outs

Anya also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Anya restrict its processing of user personal data.

1. Privacy settings

Settings menus in the Anya app for users give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from Anya. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

•   Location data

Location data helps improve our services, navigation, and customer support.

Users may enable or disallow Anya to collect location data from their mobile devices through the Settings > Privacy menus in the Anya app. Users and delivery recipients can enable or disallow such collections through the settings on their mobile devices.

•   Notifications: account updates

Anya provides users with updates related to activity on their accounts. These notifications are a necessary part of using the Anya app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menus in the Anya app.

•   Notifications: discounts and news

Users may enable Anya to send push notifications about discounts and news from Anya. Push notifications may be enabled or disabled through the Settings > Privacy menus in the Anya Web-app.

1. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the Anya app requests permission to access certain types of data and give users the option to grant or refuse permission. Android devices notify users of the permissions that the Anya app seeks before their first use of the app, and the use of the app constitutes a grant of such permission.

1. Rating look-up

After every sale, drivers and riders are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, customer’s ratings are available to media owners from whom they request products and services, and media owner’s ratings are available to their customers.

This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for customers and media owners.

1. Marketing opt-outs

Users may opt-out of receiving promotional emails from Anya. Users may also opt-out of receiving emails and other messages from Anya by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their accounts.

1. User data requests

Anya provides users with a variety of ways to learn about, control, and submit questions and comments about Anya’s handling of their data. Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.

•   Receiving data: Users can ask for a copy of data that Anya collects from them with their consent or as necessary to provide our services.
•   Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Anya’s apps. They may also ask that Anya change or update their data, including if they believe such data is inaccurate or incomplete.
•   Deleting data: Users may request the deletion of their account at any time through the Settings > Privacy menus in the Anya app, or through Anya’s website.
•   Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. Anya may continue to process data after such objection or request to the extent required or permitted by law.

In addition, depending on their location, users may have the right to file a complaint relating to Anya’s handling of their personal data with the data protection authority in their country.

 

1. Updates to this notice

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Anya apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, the use of our services by users will be understood as consent to the updates to the extent permitted by law.