WELLONGE APP PRIVACY POLICY
This Privacy Policy sets out how we, Wellonge, use and protect your personal data that you provide to us, or that is otherwise obtained or generated by us, in connection with your use of our messaging and posting services (the “Services”). For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ refers to Wellonge, and ‘you’ refers to you, the user of the Services.
1.1 Privacy Principles
Wellonge app has two fundamental principles when it comes to collecting and processing private data:
We also use your data to show you ads.
We store the data that Wellonge needs to function as a secure and feature-rich service.
1.2. Terms of Service.
This Privacy Policy forms part of our Terms of Service, which describes the terms under which you use our Services and which are available at https https://document.wellonge.com/doc/privacy-policy This Privacy Policy should therefore be read in conjunction with those terms.
1.3. Table of Contents
This Privacy Policy explains the following:
We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.
The protection of personal information with the aim of setting the minimum level of requirements for the collection and processing the personal information, was establishing a commission for the protection of personal information, the protection of personal information was processed by Government agencies and institution personal. The law was enacted by the Tanzania legislature, The Personal Data Protection Act No. 11/2022. The law will be used in Tanzania Mainland and Zanzibar except for Zanzibar it will not be used for non-union.
The right to privacy is a fundamental right enshrined in many constitutions around the world, as well as in international human rights law. The right to privacy is multifaceted, but a fundamental aspect of it, increasingly relevant to people’s lives, is the protection of individuals’ data. As early as 1988, the UN Human Rights Committee, the treaty body charged with monitoring implementation of the International Covenant on Political and Civil Rights (ICCPR), recognized the need for data protection laws to safeguard the fundamental right to privacy recognized by Article 17 of the ICCPR.
3.1. Basic Account Data
Wellonge is an All-In communication and information service. You provide your mobile number or email and basic account data (which may include profile name, profile picture and cover, location, interests and about information) to create a Wellonge account.
To make it easier for your contacts and other people to reach you and recognize who you are, the screen name you choose, your profile pictures, and your username (should you choose to set one) on Wellonge are always public. It’s better to know your real name, gender, marital status, interests, hobbies, age or what you like.
We do not require your screen name to be your real name. Note that users who have you in their contacts will see you by the name they saved and not by your screen name. This way your mother can have the public name 'Johnny Depp' while appearing as 'Mom' to you and as 'Boss' to her underlings at work (or the other way around, depending on how these relationships are structured).
3.2. Your E-mail Address
When you register using email or enable 2-step-verification for your account or store documents using the Wellonge Passport feature, you can opt to set up a password recovery email. This address will only be used to send you a password recovery code if you forget it. That's right: no marketing or “we miss you” bullshit.
3.3. Your Messages.
3.3.1. Server Chats
Wellonge is a server service. We store messages, photos, videos and documents from your server chats on our servers so that you can access your data from any of your devices anytime without having to rely on third-party backups. All data is stored heavily encrypted and the encryption keys in each case are stored in several other data centers in different jurisdictions. This way local engineers or physical intruders cannot get access to user data.
3.3.2. Secret Chats
Secret chats use end-to-end encryption. This means that all data is encrypted with a key that only you and the recipient know. There is no way for us or anybody else without direct access to your device to learn what content is being sent in those messages. We do not store your secret chats on our servers. We also do not keep any logs for messages in secret chats, so after a short period of time we no longer know who or when you messaged via secret chats. For the same reasons secret chats are not available in the server — you can only access those messages from the device they were sent to or from.
3.3.3. Media in Secret Chats
When you send photos, videos or files via secret chats, before being uploaded, each item is encrypted with a separate key, not known to the server. This key and the file’s location are then encrypted again, this time with the secret chat’s key — and sent to your recipient. They can then download and decipher the file. This means that the file is technically on one of Wellonge servers, but it looks like a piece of random indecipherable garbage to everyone except for you and the recipient. We don’t know what this random data stands for and we have no idea which particular chat it belongs to. We periodically purge this random data from our servers to save disk space.
3.3.4. Public Chats In addition to private messages;
Wellonge also supports public channels and public groups. All public chats are server chats Like everything on Wellonge, the data you post in public communities is encrypted, both in storage and in transit — but everything you post in public will be accessible to everyone.
3.4. Phone Contacts:
We store your up-to-date contacts in order to notify you as soon as one of your contacts signs up for Wellonge and to properly display names in notifications. We only need the number and name (first and last) for this to work and store no other data about your contacts.
Our automatic algorithms can also use anonymized sets of phone numbers to calculate the approximate number of potential contacts an unregistered phone number may have on Wellonge. When you open the 'Invite friends' interface, we display the resulting statistics next to your contacts to give you an idea of who could benefit most from joining Wellonge.
You can always stop syncing contacts or delete them from our servers in Settings > Privacy & Security > Data Settings.
3.5. Location Data
If you share a location in a chat, this location data is treated like other messages in server or secret chats respectively.
If you share your Live Location in any chat or turn on ’Make Myself Visible’ in People Nearby, Wellonge will use your data to display your location to those users with whom you are sharing it, even when the app is closed – for as long as you keep these optional features activated.
If you are using Android, Wellonge will ask you for permission to access your phone Location in the background, if you grant this permission to us, Wellonge will have access to your location which will be used based on the time set by user.
3.6. Cookies
The only cookies we use are those to operate and provide our Services on the web. We do not use cookies for profiling or advertising. The cookies we use are small text files that allow us to provide and customize our Services, and in doing so provide you with an enhanced user experience. Your browser should allow you to control these cookies, including whether or not to accept them and how to remove them. You may choose to block cookies with your web browser, however, if you do disable these cookies, you will not be able to log in to Wellonge Web.
4.1. Storing Data
If you signed up for Wellonge from the anywhere, your data is stored in data centers in the Tanzania. These are third-party provided data centers in which Wellonge rents a designated space. However, the servers and networks Wellonge owns that sit inside these data centers and on, which your personal data is stored. As such, we do not share your personal data with such data centers. All data is stored heavily encrypted so that local Wellonge engineers or physical intruders cannot get access.
4.2. End-to-End Encrypted Data
Your messages, media and files from secret chats, as well as the contents of your calls and the data you store in your Wellonge Passport are processed only on your device and on the device of your recipient. Before this data reaches our servers, it is encrypted with a key known only to you and the recipient. While Wellonge servers will handle this end-to-end encrypted data to deliver it to the recipient – or store it in the case of Wellonge Passport data, we have no ways of deciphering the actual information. In this case, we neither store nor process your personal data, rather we store and process random sequences of symbols that have no meaning without the keys which we don’t have.
4.3. Retention
Unless stated otherwise in this Privacy Policy, the personal data that you provide us will only be stored for as long as it is necessary for us to fulfill our obligations in respect of the provision of the Services.
The Personal Data Protection Act 2022, recognizes both the need to protect individuals’ personal data and the need of organizations to collect, use or disclose personal data for legitimate and reasonable purposes. A data protection regime is necessary to safeguard personal data from misuse and to maintain individuals’ trust in organizations that manage their data.
5.1. Our Services
Wellonge is a All-In communication and information service, We will process your data to deliver your server chat history, including messages, media and files, to any devices of your choosing without a need for you to use third-party backups or server storage.
5.2. Safety and Security
Wellonge supports massive posting and communities which we have to police against abuse and Terms of Service violations. Wellonge also has growing users which makes it a lucrative target for spammers. To improve the security of your account, as well as to prevent spam, abuse, and other violations of our Terms of Service, we may collect metadata such as your IP address, devices and Wellonge apps you've used, history of username changes, etc. If collected, this metadata can be kept for 12 months maximum.
5.3. Spam and Abuse
To prevent phishing, spam and other kinds of abuse and violations of Wellonge Terms of Service, our moderators may check messages that were reported to them by their recipients. If a spam report on a message you sent is confirmed by our moderators, your account may be limited from contacting strangers – temporarily or permanently.
5.4. Cross-Device Functionality
We may also store some aggregated metadata to create Wellonge features that work across all your devices.
5.5. Advanced features
We may use some aggregated data about how you use Wellonge to build useful features. For example, when you open the Search menu, Wellonge displays the people you are more likely to message in a box at the top of the screen. To do this, we calculate a rating that shows which people you message frequently. A similar rating is calculated for inline bots so that the app can suggest the bots you are most likely to use in the attachment menu (or when you start a new message with “@”). To turn this feature off and delete the relevant data, go to Settings > Privacy & Security > Data Settings and disable “Suggest Frequent Contacts”.
5.6. No Ads Based on User Data
Most Like other services, we might use your data for ad targeting or other commercial purposes. Wellonge stores the information it needs to function as a secure and feature-rich server service.
Wellonge offers a tool for advertisers to promote their business and profiles in public one-to-many channels, but these sponsored ads are based solely on the topic of the public channels in which they are shown. User data is mined or analyzed to display ads or sponsored business and profiles.
8.1. Other Wellonge Users
Other users of our Services with whom you choose to communicate with and share certain information, who may be located outside the EAC. Note that by entering into the Terms of Service and choosing to communicate with such other users of Wellonge you are instructing us to transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy. We employ all appropriate technical and organizational measures (including encryption of your personal data) to ensure a level of security for your personal data that is appropriate to the risk.
Wellonge Data Policy:
This Policy describes the information we process to support Wellonge and other products and features offered by HamiNass Media and Entertainment Limited through Wellonge product. You can find additional tools and information in the Wellonge settings.
What specific information do we collect?
To support the HamiNass media Products, we must process information about you. The type of information that we collect depends on how you use our Products. You may learn how to access and delete information that we collect by visiting the Wellonge through your app settings.
Things that you and other users do and provide.
Information and content you provide. We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content and message or communicate with others. This can include information in or about the content that you provide (e.g., metadata), such as the location of a photo or the date a file was created. It can also include what you see through features that we provide, such as our camera, so we can do things such as photo filters, GPS coordinates for location to connect you with people closer to you that you might like.
Our systems automatically process content and communications that you and others provide to analyses context and what's in them for the purposes described below. Learn more about how you can control who can see the things you share.
Data with special protections: You can choose to provide information in your Wellonge profile fields or life events about your religious views, political views, who you are "interested in" or your health.
Networks and connections. We collect information about the people, business, accounts and hashtags that you are connected to and how you interact with them across our Product, such as people you communicate with the most that you are part of. We also collect contact information if you choose to upload, sync or import it from a device (such as an address contacts ), which we use for things such as helping you and others find people you may know and for the other purposes listed below.
Your usage. We collect information about how you use our Products, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Products, and what posts, videos and other content you view on our Products. We also collect information about how you use features such as our camera.
Information about transactions made on our Products. If you use our Products for purchases or other financial transactions (such as when you make a purchase subscription, we collect information about the purchase or transaction. This includes payment information, such as your credit or debit card number, mobile transaction number and other card information, other account and authentication information, and contact details.
Things others do and information that they provide about you. We also receive and analyses content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you or upload, sync or import your contact information.
Device information.
As described below, we collect information from and about the phones and other web-connected devices you use that integrate with our Products, we combine this information across different devices that you use. For example, we use information collected about your use of our Products on your phone to better personalize the content (including ads) or features that you see when you use our Products on another device, such as your tablet, or to measure whether you took an action in response to an ad that we showed you on your phone on a different device.
Information that we obtain from these devices includes:
Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, app and file names and types, and plugins.
Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
Identifiers: unique identifiers, device IDs and other identifiers, such as from apps or accounts that you use, and Family Device IDs (or other identifiers unique to HamiNass Media Company Products associated with the same device or account).
Device signals: Bluetooth signals, information about nearby Wi-Fi access points, beacons and mobile phone masts.
Data from device settings: information that you allow us to receive through device settings that you turn on, such as access to your GPS location, camera or photos.
Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network, so we can do things such as help you stream a video from your phone.
Cookie data: data from cookies stored on your device, including cookie IDs and settings. Learn more about how we use cookies in the Wellonge Cookies Policy.
Information from partners.
Our Advertisers and app developers can send us information
through Wellonge Business Tools that they use, including our social plugins (such as the Like button), Wellonge Login, our APIs and SDKs. These partners provide information about your activities off Wellonge – including information about your device, websites you visit, purchases you make, the ads you see and how you use their services – whether or not you have a Wellonge account or are logged in to Wellonge. For example, app developer could use our API to tell us what things you are interested to, or a business could tell us about a purchase you made in its shop. We also receive information about your online and offline actions and purchases from third-party data providers who have the rights to provide us with your information.
Partners receive your data when you visit or use their services or through third parties that they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us.
To learn more about how we use cookies in connection with Wellonge Business Tools, review the Wellonge Cookie Policy.
How do we use this information?
We use the information that we have (subject to choices you make) as described below, and to provide and support the Wellonge Products and related services described in the Wellonge Terms of Service.
Here's how: Provide, personalize and improve our Products.
We use the information that we have to deliver our Products, including to personalise features and content (including your News Feed, Wellonge PicTalks and ads) and make suggestions for you (such as business you may be interested in or people you may want to follow) on and off our Products. To create personalised Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data that we collect and learn from you and others (including any data with special protections that you choose to provide where you have given your explicit consent); how you use and interact with our Products; and the people, places or things that you're connected to and interested in on and off our Products. Learn more about how we use information about you to personalise your Wellonge experience, including features, content and recommendations in Wellonge Products; you can also learn more about how we choose the ads that you see.
Information across Wellonge Products and devices: We connect information about your activities on different Wellonge Products and devices to provide a more tailored and consistent experience on all Wellonge Products that you use, wherever you use them. For example, we can suggest that you join a business on Wellonge that includes people you follow or communicate with using Discover.
Location-related information: We use location-related information – such as your current location, where you live, the places you like to go, and the businesses and people you're near – to provide, personalise and improve us.
Products, including ads, for you and others. Location-related information can be based on things such as precise device location (if you've allowed us to collect it), IP addresses and information from your and others' use of Wellonge Products (such as check-ins or place you attend).
Product research and development: We use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
Ads and other sponsored content: We use the information we have about you – including information about your interests, actions and connections – to select and personalise ads, offers and other sponsored content that we show you.
Promote safety, integrity and security.
We use the information that we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off Wellonge Products. For example, we use data that we have to investigate suspicious activity or breaches of our Terms or Policies, or to detect when someone needs help. To learn more, visit the Wellonge Security Help Centre.
Communicate with you.
We use the information that we have to send you marketing communications, communicate with you about our Products and let you know about our Policies and Terms. We also use your information to respond to you when you contact us.
Research and innovate for social good.
We use the information that we have (including from research partners who we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.
How is this information shared?
Your information is shared with others in the following ways:
Sharing on Wellonge Products.
People and accounts that you share and communicate with
When you share and communicate using our Products, you choose the audience for what you share. For example, when you post on Wellonge, you select the audience for the post, such as tagging your friends, the public or a customised list of people. Similarly, when you use chat to communicate with people or businesses, those people and businesses can see the content you send. Your network can also see actions that you have taken on our Products, including engagement with ads and sponsored content. We also let other accounts see who has viewed their Wellonge PicTalks or profiles.
Public information: can be seen by anyone, on or off our Products, including if they don't have an account. This includes your Wellonge username, any information you share with a public audience, information in your public profile on Wellonge, and content you share on a Wellonge business, or any other public forum, such as Wellonge shop place.You, other people using Wellonge, and we can provide access to or send public information to anyone on or off our Products, including in other HamiNass media Products, in search results or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs and offline media and by apps, websites and other services that integrate with our Products.
Content that others share or reshare about you:
You should consider who you choose to share with, because people who can see your activity on our Products can choose to repost it with others on and off our Products, including people and businesses outside the audience that you shared with. For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot or repost that content to others across or off our Products. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content, and that person can change the audience later.
People can also use our Products to create and share content about you with the audience they choose. For example, people can share a photo of you in a PicTalks or mention, tag you at a location in a post or share information about you in their posts or messages. If you are uncomfortable with what others have shared about you on our Products, you can learn how to report the content.
Information about your active status or presence on our Products.
People in your networks can see signals telling them whether you are active on our Products, including whether you are currently active on Wellonge, or when you last used our Products.
Devices and operating systems providing native versions of Wellonge (i.e. where we have not developed our own first-party apps) will have access to all information that you choose to share with them, including information that your friends share with you, so they can provide our core functionality to you.
Note: We are in the process of restricting developers' data access even further to help prevent abuse. For example, we will remove developers' access to your Wellonge data if you haven't used their app in three months, and we are changing login, so that in the next version, we will reduce the data that an app can request without app review to include only name, Wellonge username and bio, profile photo and email address. Requesting any other data will require our approval.
Product New ownership.
If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.
Sharing with third-party partners
We work with third-party partners who help us provide and improve our Products or who use Wellonge Business Tools to grow their businesses, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties that we share information with: Partners who use our analytics services.
We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, listings, Business, videos and other content on and off the Wellonge Products. For example, Business admins and Wellonge business profiles receive information about the number of people or accounts who viewed, reacted to or commented on their posts, as well as aggregate demographic and other information that helps them understand interactions with their Page or account.
Advertisers.
We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general demographic and interest information to advertisers (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Madrid and likes software engineering) to help them better understand their
audience. We also confirm which Wellonge ads led you to make a purchase or take an action with an advertiser.
Measurement partners.
We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.
Partners offering goods and services in our Products.
When you subscribe to receive premium content, or buy something from a seller in our Products, the content creator or seller can receive your public information and other information that you share with them, as well as the information needed to complete the transaction, including shipping and contact details.
Vendors and service providers.
We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys.
Researchers and academics.
We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that supports our business or mission and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.
Law enforcement or legal requests.
We share information with law enforcement or in response to legal requests in the circumstances outlined below.
Learn more about how you can control the information about you that you or others share with third-party partners in the Wellonge settings.
What is our legal basis for processing data?
We collect, use and share the data that we have in the ways described above:
as necessary to fulfil our Wellonge Terms of Use. consistent with your consent, which you may revoke at any time through the Wellonge settings.
as necessary to comply with our legal obligations; to protect your vital interests, or those of others as necessary in the public interest and as necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalised, safe and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
How can you exercise your rights provided under the GDPR?
Under the General Data Protection Regulation, you have the right to access, rectify, port and delete your data. Learn more about these rights and find out how you can exercise your rights in the Wellonge settings. You also have the right to object to and restrict certain processing of your data. This includes:
the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications, and the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right on Wellonge.
Data retention, account deactivation and deletion
We store data until it is no longer necessary to provide our services and HamiNass Media Products or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, when you search for something on Wellonge, you can access and delete that query from within your search history at any time, but the log of that search is deleted after six months. If you submit a copy of your valid photo ID for account verification purposes, we delete that copy 90 days after submission. Learn more about deletion of content that you have shared and cookie data obtained through social plugins.
When you delete your account, we delete things that you have posted, such as your photos and PicTalks updates, and you won’t be able to recover this information later. Information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using the Products, you can deactivate your account instead. To delete your account at any time, please visit the Wellonge settings.
How do we respond to legal requests or prevent harm?
We access, preserve and share your information with regulators, law enforcement or others:
In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction and is consistent with internationally recognised standards.
When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorised use of the Products, breaches of our Terms or Policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.
Information that we receive about you (including financial transaction data related to purchases made with Wellonge) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation or investigations of possible breaches of our Terms or Policies, or otherwise to prevent harm. We also retain information from accounts disabled for term breaches for at least a year to prevent repeat abuse or other term breaches.
How do we operate and transfer data as part of our global services?
We share information globally, both internally within the Wellonge Companies and externally with our partners and with those you connect and share with around the world in accordance with this Policy. Information controlled by HamiNass media and entertainment Limited will be transferred or transmitted to, or stored and processed in, the United Republic of Tanzania - Zanzibar Island or other countries outside where you live for the purposes as described in this Policy. These data transfers are necessary to provide the services set forth in the Wellonge Terms and to globally operate and provide our Products to you.
How will we notify you of changes to this Policy?
We'll notify you before we make changes to this Policy and give you the opportunity to review the revised Policy before you choose to continue using our Products.
How to contact Wellonge with questions
You can learn more about how privacy works on Wellonge If you have questions about this Policy, you can contact us as described below. We may resolve disputes that you have with us in connection with our Privacy Policies and practices through our law Department.
Contact us:
The data controller responsible for your information is HamiNass Media and Entertainment Limited, which you can contact online or by post at through contract form:
HamiNass Media and Entertainment Limited, Zanzibar – Tanzania, Mwanakwekwe – Kificho Building Ground Floor.
Data Protection:
Essential for Exercise of Right to Privacy is an internationally recognized human right. Article 12 of the Universal Declaration of Human Rights (UDHR) proclaims that
“No one shall be subjected to arbitrary interference with his privacy, family, and home or correspondence everyone has the right to the protection of the law against such interference or attacks”.
1988, the UN Human Rights Committee, the treaty body charged with monitoring implementation of the ICCPR, recognized the need for data protection laws to safeguard the fundamental right to privacy recognized by Article 17 of the ICCPR:
“The gathering and holding of personal information on computers, data banks, and other devices, whether by public authorities or private individuals or bodies, must be regulated by law. ... [E]very individual should have the right to ascertain in an intelligible form, whether, and if so, what personal data is stored in automatic data files, and for what purposes. Every individual should also be able to ascertain which public authorities or private individuals or bodies control or may control their files. If such files ... have been collected or processed contrary to the provisions of the law, every individual should have the right to request rectification or elimination”
In 2011, the then-UN “the protection of personal data represents a special form of respect for the right to privacy. The report further noted that:
“The necessity of adopting clear laws to protect personal data is further increased in the current information age, where large volumes of data are collected and stored by intermediaries, and there is a worrying trend of States obliging or pressuring these private actors to hand over information of their users”
“The purpose of this Convention is to protect every individual, whatever his or her nationality or residence, with regard to the processing of their personal data, thereby contributing to respect for his or her human rights and fundamental freedoms, and particular the right to privacy.”