BOLINGO CONSULT PRIVACY POLICY
Last updated [January 25, 2023]
1.0 INTRODUCTION
1.1 Bolingo Consult means Bolingo Communications and Media Consult LTD, Bolingo Communications and Media Consult LLC, and all their affiliates and subsidiaries.
1.2 Bolingo Consult (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information, including any nonpublic personal information when you visit any of our websites mentioned in section 1.3 below. Please read this privacy policy carefully.
1.3 This Privacy Policy applies to the services provided by Bolingo Consult and applies to users of our websites, products and other online services to which this Privacy Policy is posted. This Privacy Policy covers all Bolingo Consult websites (“Site”) which includes the following domains and subdomains:
1.3.1 www.bolingoconsult.com
1.3.2 www.voices.bolingoconsult.com
1.3.3 www.localizationafrica.com
1.3.4 www.podcast.localizationafrica.com
1.3.5 www.akannews.com/asante-twi
1.3.6 www.akannews.com/fante
1.3.7 www.books.bolingoconsult.com
1.4 We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. Your continued use of our website will be deemed acceptance of any such changes or updates to this Privacy Policy.
1.5 You are encouraged to periodically review this Privacy Policy to stay informed of updates, our information practices and the ways you can help protect your privacy. This Privacy Policy is part of our Terms of Use. By choosing to use our services, you agree to Bolingo Consult collecting and processing your information as described in this Privacy Policy. We will not use or share your information with anyone except as described in this Privacy Policy.
1.6 You may browse parts of our websites without providing any information about yourself and without accepting cookies. In that case, it is unlikely we will possess and process any information relating to you.
2.0 COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect on the website includes:
Personal Data
Personally identifiable information, such as your name, phone number, email address, and demographic information, such as your gender, hometown, and interests, that you voluntarily give to us when you browse through the Site and fill a form to request for any resources on the Site. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from accessing certain resources on the Site.
Location Information
Information about your precise location that we collect from your device (collected in limited circumstances) or information about your general location derived from your IP address.
Derivative Data
Information our servers automatically collect when you access the website, such as your IP address, Hash I.D., advertising ID, unique device ID, your browser type, your operating system, other information about your device, your access times, the pages you have viewed directly before and after accessing the Site, and internal and third-party IDs that have been assigned to you.
Internet Activity Information
Information about your use of our services, your interactions with the emails we send to you, and your activities on other websites you visit, including the web pages, content, and advertisements you view and links you click on, and whether you open, forward, or click the links in emails we send to you; your browsing history; and social media you use, including the “shares” and “likes” you make on a social media platform that is connected to the services.
Data From Contests, Giveaways, and Surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
Depending on how you use our website, services, and products, you will be subject to different types of Personal Data collected and different manners of collection.
- Registered users
You, as a user of our website, products and services, may be asked to register to use our website, services, and resources in a legal manner. During the process of your registration, we will collect some of the following Personal Data from you through your voluntary disclosure. Personal Data may be asked for concerning:
- Interaction with our representatives in any way
- receiving notifications by text message or email about marketing
- receiving general emails from us
By undergoing the registration process, you consent to us collecting your Personal Data, including the Personal Data described in this clause, as well as storing, using, or disclosing your Personal Data under this Privacy Policy.
- Unregistered users
If you are a passive user of our website, or services, and do not register at all, you may still be subject to certain passive data collection (“Passive Data Collection”). Such Passive Data Collection may include through cookies, as described below, IP address information, location information, and certain browser data, such as history and/or session information.
- All users
The Passive Data Collection that applies to Unregistered users shall also apply to all other users and/or visitors of our website, services, and resources.
- Related Entities
We may share your Personal Data, including Personal Data that identifies you personally, with any of our parent companies, subsidiary companies, affiliates, or other trusted related entities.
However, we only share your Personal Data with a trusted related entity if that entity agrees to our privacy standards as set out in this Privacy Policy and to treat your Personal Data in the same manner that we do.
- Email Marketing
You may be asked to provide certain Personal Data, such as your name and email address, to receive email marketing communications. This information will only be obtained through your voluntary disclosure and you will be asked to affirmatively opt-in to email marketing communications.
- User Experience
From time to time we may request information from you to assist us in improving our website, services, and applications, such as demographic information or your particular preferences.
3.0 USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience on our websites, services and resources, and to provide you with the services/information you may have requested, such as the use of our websites, services and resources.
Information that does not identify you personally, but that may assist in providing us with broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include but is not limited to, interests based on your cookies.
Specifically, we may use information collected about you via our websites to:
- Administer promotions, and contests.
- Improve your personal user experience.
- Fulfill your requests for services and information.
- Provide customer service to you.
- Comply with legal obligations under applicable laws and regulations..
- Compile anonymous statistical data and analysis for use internally or with third parties.
- Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and our websites to you.
- Increase the efficiency and operation of the websites.
- Monitor and analyze usage and trends to improve your experience with the websites.
- Notify you of updates to the websites.
- We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance. Before doing that, we will always tell you our intentions and of the specific purpose of making the recording.
- Offer new products, services, and/or recommendations to you.
- Perform other business activities as needed.
- Request feedback and contact you about your use of the websites.
4.0 DISCLOSURE OF YOUR INFORMATION
Although our policy is to maintain the privacy of your personal data as described herein, we may share information we have collected about you if we believe that it is reasonable to do so in certain situations, at our sole and exclusive discretion. Such situations may include but are not limited to:
To Satisfy Any Local, State or Federal Laws or Regulations or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including data analysis, hosting services, customer service, and marketing assistance.
We may employ companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above, for example, for reviewing and accepting applications, processing payments, sending postal mail and email, analyzing data, providing marketing assistance, providing search results and links and providing customer service. Those parties will be bound by strict contractual provisions with us and will only have access to personal information needed to perform their functions, and they may not use it for any other purpose. Further, they must process the personal information in accordance with this Notice and as permitted by the Data Protection Regulation.
Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business Partners
We may share your information with our business partners to offer you certain products, services or promotions.
Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law. In this instance, the third party will have access to your personal data. We only share your personal data with a third party if that third party agrees to our privacy standards as set out in this Privacy Policy. Your personal data will not be transferred to other third parties without your approval.
Notwithstanding the other provisions of this Privacy Policy, we may provide your personal data to a third party or third parties to protect the rights, property or safety of us, our users or third parties, or as otherwise required by law. We will not knowingly share your personal data with any third party other than under this Privacy Policy. If your personal data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we do not share that information.
Business Transfers
If we reorganize or sell all or a portion of our assets, undergo a merger, consolidation, change in control, liquidation, or are acquired or are in the process of being acquired by another entity, we may transfer your information to the successor entity. . You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
5.0 WITHDRAW YOUR CONSENT
You may withdraw your consent or object at any time to the processing of your personal information and we will stop processing your personal information. The withdrawal of consent does not affect the lawfulness of processing based on your prior consent before its withdrawal.
We will get your express opt-in consent before we share your personal data with any company outside Bolingo Consult for marketing purposes. If you opt-in to receive marketing materials from a company outside Bolingo Consult, we recommend that you read their privacy policy to see how they will use your data and how to alter your marketing preferences with them should you wish to in the future.
From time to time, we may send you informational or marketing communications related to our website, services, and applications such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email address [info@bolingoconsult.com]. You may also click the opt-out link which will be provided at the bottom of all such communications.
Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our website, services, and resources or your account with us.
By providing any Personal Data to us, or by using our website, services, and resources in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.
6.0 TRACKING TECHNOLOGIES
Cookies and Web Beacons
We may collect information from you through cookies, web beacons, tracking pixels, and other automatic tracking technologies on our websites as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using our website, services, and resources as described above).
For example, we use cookies to make your browsing experience easier and more intuitive: Cookies are small strings of text used to store some information that may concern the user, his or her preferences, or the device they are using to access the internet (such as a computer, tablet, or mobile phone). Cookies are mainly used to adapt the operation of the Site to your expectations, offering a more personalized browsing experience and memorizing the choices you made previously.
A cookie consists of a reduced set of data transferred to your browser from a web server and it can only be read by the server that made the transfer. This is not executable code and does not transmit viruses. When you access the website, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the website. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.
- Technical cookies
Technical cookies, which can also sometimes be called HTML cookies, are used for navigation and to facilitate your access to and use of the Site. They are necessary for the transmission of communications on the network or to supply services requested by you. The use of technical cookies allows for the safe and efficient use of the Site.
You can manage or request the general deactivation or cancellation of cookies through your browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the Site.
Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit our website, services, and resources. These are also considered technical cookies when they operate as described.
We use both Permanent and Session cookies. Permanent cookies remain on your computer or mobile device when you go offline. Session cookies are deleted as soon as you close your web browser.
- Third-party cookies
We may also utilize third-party cookies, which are cookies sent by a third party to your computer. Permanent cookies are often third-party cookies. The majority of third-party cookies consist of tracking cookies used to identify online behavior, understand interests and then customize advertising for users.
Third-party analytical cookies may also be installed. They are sent from the domains of the aforementioned third parties external to the Site. Third-party analytical cookies are used to detect information on user behavior on our website and services. This takes place anonymously, to monitor the performance and improve the usability of the Site. Third-party profiling cookies are used to create profiles relating to users, and to propose advertising in line with the choices expressed by the users themselves.
- Profiling cookies
We may also use profiling cookies, which are those that create profiles related to the user and are used to send advertising to the user’s browser.
When these types of cookies are used, we will receive your explicit consent.
To learn more about cookies, you may wish to visit: www.allaboutcookies.org or www.google.com/policies/technologies/cookies/.
- Support in configuring your browser
You can manage cookies through the settings of your browser on your device. However, deleting cookies from your browser may remove the preferences you have set for using our website and services.
- Log Data
Like all websites and mobile applications, our website, services, and resources also make use of log files that store automatic information collected during user visits.
The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner to verify the correct functioning of the Site, and for security reasons. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, under applicable laws, to block attempts at the damage to our website, services, and applications or damage to other users, or in the case of harmful activities or crime. Such data is never used for the identification or profiling of the user, but only for the protection of our website, services, applications, and our users.
7.0 RETENTION OF YOUR PERSONAL INFORMATION
We keep your personal information for as long as is required in order to fulfill the relevant purposes described in this Privacy Policy, comply with the applicable laws and regulations, or as otherwise communicated to you.
8.0 INTERNATIONAL TRANSFERS
Your information, including personal data that we collect from you may be transferred to, processed and stored at, a destination outside the country you are resident in or the country, state, province or other governmental jurisdiction in which you provided it to us.
Your consent to this Privacy Policy followed by your submission of your information, represents your agreement to this transfer, storing and or processing. We will take all steps reasonably necessary to ensure that your information is processed securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to a country unless there are adequate controls in place including the security of your personal data.
9.0 THIRD-PARTY WEBSITES
Our websites may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. You may also be redirected to such third party websites as the user. Additionally, links to our websites may be featured on third-party websites on which we advertise. Bolingo Consult expressly disclaims any and all liability or responsibility whatsoever with respect to third-party websites you access, including, but not limited, to any information displayed or distributed on/by the websites, deficiency in services, erroneous submission of data or information, or any virus, malware or phishing attacks.
Except as provided herein, we will not provide any of your personal information to these third parties without your consent. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use, which we recommend you read carefully. . We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from our websites. Therefore, we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure, or otherwise treat your personal information.
10.0 SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
11.0 YOUR LEGAL RIGHTS
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your personal information. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please note that this may amount to a termination of your right to use the website.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact info@bolingoconsult.com
- No fee is usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
These rights can all be exercised by contacting us at info@bolingoconsult.com
These rights may be limited in some situations, for instance, where we can demonstrate we have a legal requirement to process your personal data.
12.0 ACCEPTANCE OF RISK
By continuing to use our website, services, and resources in any manner, you manifest your continuing assent to this Privacy Policy. You further acknowledge, agree, and accept that no transmission of information or data via the internet is always completely secure, no matter what steps are taken. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. You acknowledge, agree, and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk. We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.
13.0 POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.
Phone Numbers: +233 502 960 485 / +1 302 546 5137
Email: info@bolingoconsult.com
14.0 CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
15.0 CONTACT US
If you have questions or comments about this Privacy Policy, please contact us via:
Phone Numbers: +233 502 960 485 / +1 302 546 5137
Email: info@bolingoconsult.com