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At LaRedmond Nigeria, our mission is to seek the truth and help people understand the world. We want you to understand how we handle your personal information. We also want you to know your rights and choices.

This policy describes how we handle your personal information when you use the following “theleadway Services”:

• The The Leadway Magazine print Edition
• Our websites, like theleadway.ng
• Our email newsletters
• Our pages or ads on social media networks, like our Facebook and Instagram pages
• Anywhere we gather information from or about you and refer you to this Privacy Policy

How we handle information about you depends on which theleadway Services you use and how you use them. For example, we use different information about print subscribers than website visitors.

Be aware that certain theleadway Services work differently. Some have additional terms that supplement this policy (e.g., Reader Submissions). 

If you have questions, please don’t hesitate to contact us at privacy@theleadway.ng. You can also review our Privacy F.A.Q.

1. What Information Do We Gather About You?

The information we gather about you depends on the context. By and large, it’s information about you that can personally identify you — either on its own or when combined with other information.

The following describes the information we collect and how we obtain it.

1. (A) Information Collected through theleadway Services

i. Information You Voluntarily Give Us

• For Registration

When you sign up for a theleadway Service (whether via a subscription or a free account as a registered user), we collect personal identifiers such as your contact information, including your name and email address, and account credentials. We may also ask you to create an account or display name and select a profile picture. Once you’re registered, we assign you a unique ID number. This ID number helps us recognize you when you’re signed in.

For some theleadway Services, you can instead sign up by linking your Apple, Facebook or Google account. See Information Collected From Other Sources below.

If you enroll in a Family Subscription, we will collect the contact information you provide for each subsidiary account holder when you invite them to access the subscription.

If you register for an event or conference, we might ask for additional information (e.g., your company name, your job title or your dietary restrictions). Some events and conferences may have different or additional privacy policies and terms and we recommend that you review those before you register.

You may voluntarily choose to provide additional personal information in your User Profile.

• For Billing

To process payments or donations, we collect and use your payment information. This can include your name, your address, your telephone number, your email address, your credit or debit card information and any other relevant information.

• For User-Generated Content

We offer you the ability to post content that other users can read (e.g., comments or recipe notes). Anyone can read, collect and use any personal information that accompanies your posts. See the Comments F.A.Q., the Cooking FAQ on writing personal or public notes on recipes, and read the User-Generated Content section in our Terms of Service for more information.

We do not have to publish any of your content. If the law requires us to take down, remove or edit your content, we will comply.

In certain apps, you may be able to chat with other users of the theleadway Services through direct messages or send other users links to puzzles or games. We collect the content of those messages along with your use of any corresponding chat features—e.g., blocking, muting, or reporting another user to us. We may use automated scanning and moderation technology to monitor users’ direct messages in order to identify any violations of an applicable Acceptable Use Policy and/or our Terms of Service, to help ensure a safe and respectful experience for you and other users.

• For Contests, Sweepstakes and Special Offers; Notice of Financial Incentives

From time to time, we offer certain opportunities through contests, sweepstakes, gift cards, or other special promotions and offers. When you sign up for these, you give us your name, email and any other required information.

Some such opportunities may allow you to earn “rewards” such as discounts (“Incentive Programs”) or gift cards. If this is part of the contest, sweepstake, promotion, survey or offer, we will provide you with a full description of the Incentive Program, including the benefits offered and related legal terms. Because these Incentive Programs involve the collection of personal information, they may be interpreted as “financial incentive” programs under Nigerian law (or other similar concept under another law). We use this information for the purposes described in this Privacy Policy including for targeted advertising. We may share your personal information with third parties as described in this Privacy Policy, including data analytics providers, advertising technology vendors, and social media platforms. 

The value of any financial incentive we offer is reasonably related to the value of any personal information you provide to us. We estimate the value of your personal information by considering, without limitation, the expenses we incur from collecting your personal information and/or providing the financial incentive to you, the revenue generated by your use of the financial incentive, and any improvements we can make to our products and theleadway Services based on information obtained through the financial incentive program. 

Please note that we may provide additional terms that apply to a particular financial incentive. If applicable, those terms will be presented to you at sign up. You may cancel your membership in such Incentive Programs at any time by contacting privacy@theleadway.ng

• For Reader Surveys, Research, Panels and Experience Programs

We gather personal information through questionnaires, surveys and feedback programs. Some surveys may include gift cards when you participate, which may be financial incentives, as discussed above.

Surveys and Panels: Some of our surveys and feedback programs, including panels, will request your consent to provide on a purely voluntary basis information regarding your interests in various topics, including travel, entertainment and health and wellness, as well as demographic information, some of which may be considered sensitive under applicable laws such as your age, ethnicity, race, gender, sexual orientation, family characteristics and income. We use service provider platforms to support these programs and personal information is shared with them as described below with respect to service providers in general. We may also use survey providers that have their own independent relationship with you via third party sites or apps, whose practices we don’t control. We encourage you to review their policies.

We target these surveys based on a number of factors including information we automatically collect about your interests and usage, as described below. These surveys are used for a variety of purposes described throughout this Privacy Policy including research for marketing of Times Services, as well as research for third party advertisers that are interested in targeting ads to particular groups of Times readers. 

• During Contact with Our Customer Care teams (including Call Centers (Internal and Offshore), chat (including AI chatbots), and user reports)

We collect information from you when you place an order over the phone or contact customer service through one of our toll-free numbers or via chat. This can include your name, contact information, information about your account and any other information you choose to provide. Information you share will be shared with our service providers including call agents and technology platforms.

• Refer-a-Friend

If you’d like to invite your friends to use theleadway Services, we will store this information for the sole purposes of allowing you to send your friends referral offers, for determining whether your friends use theleadway Services after a referral is sent, and to remind your friends of the referral sent on your behalf.

iii. Information Collected Automatically

The categories of personal information we collect automatically include:

• Identifiers and Device Information

• Your IP address
• Cookie identifiers
• Your operating system and browser (e.g., type, version, and configuration)
• Your browser language
• Device identifiers (such as MAC address)
• Advertising identifiers
• The unique ID that we assign to you when you register, as described above

We collect information about certain internet and network activity on Times Services, including your interactions with our websites and apps, such as the URLs of any pages you visit on our sites and apps, the URL of the website from which you came to our sites, how long you spent on a page, access times, search queries, and other details about your use of and actions on our Services. This also includes your interactions with marketing and advertisements on Times Services.

As described elsewhere in this Policy, we may use this usage data to personalize or customize content for you that we think you might like based on your usage patterns or for other similar purposes. We may also use it to improve the Times Services — for example, this data can tell us how often users use a particular feature of the Times Services, and we can use that knowledge to make the Times Services interesting to as many users as possible. We also use this information to serve surveys or questionnaires based on your usage patterns. We combine this data with other information we collect about you.

2. What Do We Do with the Information We Collect about You?

We use each of the categories of personal information described above to operate, improve, understand and personalize our Services, and for the following business and commercial purposes. The activities below can involve outside companies, agents or contractors (“service providers”) to whom we disclose your personal information for these purposes (discussed further below in Section 3 of this Privacy Policy).

2. (A) We Provide the theleadway Services

We use your information to help you use and navigate theleadway Services, such as:

• Making a theleadway Service available to you or otherwise meeting or fulfilling the purposes for which you provided the information to us, including charging you for theleadway Services
• Arranging access to your account
• Providing customer service
• Responding to your inquiries, requests, suggestions or complaints
• Completing your payments and transactions
• Sending service-related transactional messages (e.g., a change in our Terms of Service, Terms of Sale, or other terms and conditions) and otherwise communicating with you about Times Services
• Saving your reading list, recipes or searches
• Displaying your Games (including Crossword, Wordle, Connections and Spelling Bee) stats
• Connecting you with “friends” and game opponents
• Determining your eligibility to use a Times Service or feature
• Letting you take part in paid services, polls, promotions, surveys, panels, research and comments
• Creating and managing user profiles and content.

2. (B) We Personalize Your Experience

We track your interests and reading habits (e.g., the articles you read) to personalize and calibrate your experience using technology like algorithmic recommendations and machine learning, which may include third party machine learning services or large language models. This is how we highlight articles you might be interested in and de-emphasize articles you’ve already read. For more information about content personalization on theleadway Services, you can read the Personalization F.A.Q and this blog post about how we personalize recipe recommendations. We also show you prices, promotions, products or services we believe you’ll find interesting, based on demographic and usage data, including but not limited to location data such as IP address and zip code.

2. (C) We Allow You to Share User-Generated Content

Any information you disclose in your content or otherwise via interactive functionality becomes public — along with your chosen display name or username and uploaded photo, if any. Any information you disclose via direct message is available to the recipient of that chat — along with your chosen display name and selected profile picture, if any. Your direct messages may also be monitored by our moderators and monitoring systems (or those of our vendors, if any) to assess your compliance with our Terms of Service, and any applicable Acceptable Use Policies, and other applicable terms and conditions.

2. (D) We Develop Products and Services, and Do Analysis

We analyze data on our users’ subscriptions, purchases, registered account activity and other usage behaviors. This helps us make business and marketing decisions. This allows us to understand how users interact with theleadway Services and to improve and develop theleadway Services, including testing new features, research, surveys, analysis, and product development.

2. (E) We Carry Out Administrative or Legal Tasks

• For auditing, legal or regulatory purposes: We verify that our internal processes work as intended and comply with legal, regulatory and contractual requirements. More broadly, we process information to comply with legal, regulatory and contractual obligations and to respond to law enforcement requests (our sharing for these purposes is described in Section 3 below).
• For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities, protect against or deter fraudulent, illegal, or harmful actions, and maintain the safety, security, and integrity of Times Services.
• For customer satisfaction: We assess users’ satisfaction with Times Services and our customer care team.

We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). This means we might retain your personal information even after you close your account with us.

When deciding how long to keep your information, we consider:

• How long we have had a relationship with you or provided a theleadway Service to you
• Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
• Whether we have taken any legal positions (e.g., in connection with any statutes of limitation)

Rather than delete your data, we might de-identify or mask it by removing certain identifying details.

6. How Do You Protect My Information?

We protect your personal information with appropriate organizational, technological and physical safeguards — but we cannot guarantee its absolute security. We recommend that you use complex and unique passwords for your Times accounts and for third-party accounts linked to them. Do not share your password with anyone.

If you have reason to believe your interaction with us is no longer secure, notify us immediately.

7. Are There Guidelines for Children?

theleadway Services are intended for a general audience and are not directed at children under (13) years of age.

We do not knowingly gather personal information (as defined by the Nigerian Children’s Privacy Protection Act, or COPPA) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us. We will remove the data to the extent required by applicable laws.

In certain situations, the courts, law enforcement agencies, regulatory agencies or security authorities in those countries might be entitled to access your personal information.

10. What about Third-Party Services?

Some theleadway Services contain links to third-party websites, resources, vendors and advertisers, or can be experienced via third party platforms. These third parties are not theleadway Services. Additionally, theleadway Services may be available to you through third-party digital properties such as Google’s Accelerated Mobile Pages (AMP). We do not control (and are not responsible for) third party content or privacy practices. These third parties may independently collect and solicit information about you and affect your data preferences when you access the Times Services on third-party digital properties (see “Additional Notes” below for more information). Any personal information you provide to them is not covered by this Privacy Policy. These third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their services and devices, and whether they store information in Nigeria or elsewhere.

11. How Are Changes to this Privacy Policy Communicated?

We are always improving our products and services, and we create new features regularly. These updates sometimes require us to collect new information or use what we already have differently. Further, the laws regarding personal information and privacy frequently change. As a result, we must periodically update this Privacy Policy.

We will post any changes on this page by updating this policy. If we make a significant or material change in the way we collect, use or share your personal information, we will notify you at least 30 days prior to the changes taking effect. We will do this via email or prominent notice within theleadway Services. If you object to any change, you can stop using the theleadway Services.

After we post any changes on this page, your continued use of theleadway Services is subject to the updated Privacy Policy.

12. How Can You Contact Us? Who Is the Controller of Your Personal Information?

If you have any questions, email us at magazinetheleadway@gmail.com

The LeadWay is referred to in this Privacy Policy as “The Times,” “we” or “our.”