Privacy Policy

Who we are?



Howfaa is operated by Onesign Concept LLC and we are the global pioneer of VCRW, a registered Limited Liability Company in Nigeria with RC registration number 1431112. Our registered address is Plot 0606 K-close 41 Road, 4th Avenue, Amuwo Odofin. You can contact us as indicated under the “Contact” section in the main navigation. The data controller responsible for your personal data is Onesign Concept LLC with whom you contract as a user, customer, member or membership applicant

Effective Date: January 30, 2019 This privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information' (“PII”) is being used online. PII, as described in International, Nigeria and US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

Provide name and contact details of the data controller. This will typically be your business or you, if you are a sole trader. Where applicable, you should include the identity and contact details of the controller’s representative and/or the data protection officer.

What personal information do we collect from the people that visit our website?



•Registration information. When you register to use howFaa, we collect the demographic information that you provide including your name, email address, age, gender, location, etc. We also store the information you provide for your partner: their name and email address. Neither you nor your partner’s information will be available to other howFaa users

• Billing information. If you make a payment to howFaa, we require you to provide your billing details, such as a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date). If you provide a billing address, we will regard that as the location of the account holder.

• Survey data. We store your survey data (questions and responses) for you. We keep your responses to the surveys private. •Submitted questions. Your contributed questions, if approved and added to Question Bank, become the content property of howFaa.

•Other data you intentionally share We may collect your personal information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial, or participate in a howFaa survey or contest

How do we use personal information?

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). As detailed in our Help Center, your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile. Posts, Likes, Follows, Comments, Messages Our Services allow viewing and sharing information including through posts, likes, follows and comments. When you share a post or an article (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).

In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings. Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages. When you follow a person or organization, you are visible to others and that “page owner” as a follower. We let senders know when you act on their message, subject to your settings where applicable. Subject to your settings, we let a Member know when you view their profile. When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways: • To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested. • To allow us to better service you in responding to your customer service requests. • To administer a contest, promotion, survey or other site feature. • To quickly process your transactions. • To send periodic emails regarding your order or other products and services. • To follow up with them after correspondence (email or phone inquiries) • To prevent potentially illegal activities or to screen for and prevent undesirable or abusive activity.

•To respond to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.

What is the legal basis that allows Howfaa to use my data?



We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the HowFaa Services you have requested)) and “legitimate interests”We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the HowFaa Services you have requested)) and “legitimate interests”. Learn more. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. Learn More. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. Learn More. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer

When do we share personal data?

We may share aggregated information with parties as Foursquare that includes your personal data (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services. We share your data with the following categories of third-parties: Information technology companies (hardware and software) which provide services to support our products Fraud prevention and anti-spam providers to protect the service from criminal activity Moderators to monitor activity on the site/apps and approve content Advertising partners, market places and providers of targeted advertising, including, but not limited to, MoPub Inc. (you can view MoPub’s privacy policy at https://www.mopub.com/legal/privacy/ and its partner list at https://www.mopub.com/legal/partners/) Law enforcement agencies, where we are required to by law or to protect the vital interests of a person Payment processing and telecommunications companies to facilitate payments for our "PRO" or "FLY" PACKAGE services We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible. In the event that Howfaa or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

Where do we store and process personal data?

We want you to be able to access Howfaa wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in the UK, US and China, . The hardware is located in third-party data centers but is owned by Howfaa. Data collected by advertising partners may also be held outside the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses (which can be found here), US privacy shield certification (more information can be found here); and implementing robust contractual standards.

How do we secure personal data?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

How long do we keep your personal data for?

We keep your personal information only as long as we need it for legitimate business purposes (as set out above) and as permitted by applicable law. In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless: we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations); we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years); there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

If you cannot state a specific period, you need to set out the criteria you will apply to determine how long to keep the data for (eg local laws, contractual obligations, etc)

You should also outline how you securely dispose of data after you no longer need it.

Your rights in relation to personal data

You have the right to lodge a complaint with data protection regulators anywhere. Howfaa has its main office in Nigeria and the Nigeria Communication Commission (NCC) is our lead regulator. You can find out how to raise a concern with the NCC by visiting their website at ncc.gov.ng. If you’re within the US, UK, EU, you may also get in touch with your local Data Protection Regulator who may liaise with the NCC on your behalf. You have a number of rights under European Data Protection law if you are an EU citizen. Right to be informed: what personal data an organization is processing and why (this notice). Right of access: you can request a copy of your data. Right of rectification: if the data held is inaccurate, you have the right to have it corrected. Right to erasure: you have the right to have your data deleted in certain circumstances. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing. Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

Use of automated decision-making and profiling

• Log Data: When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request. • Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features. For detailed information on the cookies and similar technologies we use, please see our Cookie Policy.

Use of cookies and other technologies

Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember your membership preferences and past transactions. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We use cookies to: • Understand and save user's preferences for future visits. • Keep track of advertisements. • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies. If you turn cookies off, some features will be disabled. It won't affect the user's experience that make your site experience more efficient and may not function properly. However, you will still be able to access HowFaa services.

Does Howfaa collect any other personal data about me?

If you contact our Customer Support team via our Feedback page, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 6 years after deletion of your account.

Third-party disclosure We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third-party links Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to: • Send information, respond to inquiries, and/or other requests or questions • Process orders and to send information and updates pertaining to orders. • Send you additional information related to your product and/or service • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred. To be in accordance with CANSPAM, we agree to the following: • Not use false or misleading subjects or email addresses. • Identify the message as an advertisement in some reasonable way. • Include the physical address of our business or site headquarters. • Monitor third-party email marketing services for compliance, if one is used. • Honor opt-out/unsubscribe requests quickly. • Allow users to unsubscribe by using the link at the bottom of each email. If at any time you would like to unsubscribe from receiving future emails, you can email us at contactus@howfaa.com and we will promptly remove you from ALL correspondence.

Contacting Us If there are any questions regarding this privacy policy, you may contact us using the information below. Send email to the following address: contactus@howfaa.com