This Privacy Notice explains how Ardenturn Limited (“Ardenturn”, “we”, “us” or “our”), operator of the ComOpp platform, collects, uses, shares and protects Personal Data in connection with contributor accounts and use of the Platform. It should be read together with the ComOpp Contributor Terms and Conditions, which take precedence on matters other than the processing of Personal Data.
Ardenturn Limited is the data controller responsible for Personal Data collected in connection with ComOpp contributor accounts and Contributions, except where we expressly identify another controller for a specific processing activity.
We collect and process the following categories of information:
We do not access or store other Google profile data beyond your name and email address, and location queries you submit to search the map are processed to return business results but are not stored permanently unless made as part of a Contribution.
We process Personal Data lawfully, fairly and transparently, only for specified and legitimate purposes, and only to the extent reasonably necessary, including to:
We may calculate an internal reliability or confidence score for Contributions, using factors such as verified accuracy, duplication, timeliness, consistency, location verification, successful challenges and substantiated fraud indicators. A reliability score is an internal risk and quality indicator only, is not based on unlawfully discriminatory factors or Sensitive Personal Data, and is not publicly represented as an allegation of dishonesty or criminality.
Where applicable law gives you a right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, we will provide meaningful human review and a reasonable opportunity for you to state your position.
Where location verification is required for a Contribution, we will show a just-in-time notice explaining what location information will be collected, why it is required, whether it is approximate or precise, whether collection is one-off, submission-based or background, how long it will be retained, and the consequence of refusing permission.
Unless you give separate, informed and revocable permission for a clearly stated purpose, we collect Location Data only while you actively make or verify a location-dependent Contribution. We do not continuously or secretly track your location merely because your account is logged in, and refusing location permission will not prevent access to unrelated Platform functions unless reasonably necessary for security. We retain precise identifiable Location Data only for as long as reasonably necessary for verification, dispute handling, fraud prevention and applicable legal obligations, and use aggregated or de-identified location information for longer-term analytics where reasonably possible.
We do not sell your Personal Data. We may disclose it only where reasonably necessary to:
If Personal Data is transferred outside Nigeria, we use appropriate lawful safeguards to protect it in accordance with applicable data-protection law.
We keep Personal Data only for as long as reasonably required for the purposes described in this Notice, to resolve disputes, to enforce our agreements, or as legally permitted or required. Location Data is subject to the shorter retention approach described in section 5. Information subject to a lawful legal hold, dispute or investigation may be retained on an access-restricted basis until the hold ends.
Subject to applicable law, you may have rights to access, correct, delete, object to or restrict the processing of your Personal Data, request portability of it, withdraw consent, and request human review of a decision based solely on automated processing. Withdrawing consent does not affect processing lawfully carried out beforehand or processing based on another lawful basis.
You may exercise these rights, or request deletion of your account and associated data, at any time by contacting us using the details in section 12.
We will only use your Personal Data for direct marketing where we have a lawful basis to do so, and we will always provide an effective way for you to object or opt out.
ComOpp is intended for contributors who are at least 18 years old. We do not knowingly collect information about a child, and we do not accept information about a child submitted as part of a Contribution unless the Platform specifically requests it for a stated lawful purpose through a separately approved process.
We use appropriate technical and organisational measures to protect Personal Data, and maintain incident-response procedures to make legally required notifications following a Personal Data breach. However, no method of transmission over the internet is 100% secure.
For privacy requests, please email help@ardenturn.com with the subject line “Privacy Request”. We may ask for reasonable information to verify your identity and protect against unauthorised disclosure. You also have the right to complain to the Nigeria Data Protection Commission or another competent supervisory authority.
We may update this Privacy Notice from time to time to reflect changes in law, security requirements, Platform functions or our operations. Where a change is material, we will provide reasonable notice before it takes effect. Continued use of ComOpp after a change takes effect constitutes acceptance of the update, without prejudice to any non-waivable statutory right.