Thank you for trusting us with your personal information (PI). We respect the fact that you hand us your PI and we want you to know that we use it according to the law and do not abuse your trust. We have an obligation under the Nigeria Data Protection Regulation (NDPR) 2019 to inform you of the PI we collect from you, how we collect it, the basis for collecting it and the use we put it to. We also have to tell you your rights under the NDPR.
ntel is a communications provider in Nigeria with a national carrier, international gateway and mobile licenses. We are a data controller. From the start of our relationship with you, we collect your PI which we use to provide our products and services to you. The kind of PI we collect is determined by our relationship with you. We want you to know that we will treat your PI with confidence, secure it against hackers and that it will always be available.
We collect your PI at the point you request a product, a service or offer to enter other relationships with us. When we collect your PI, we use it under four legal bases.
Firstly, if you request a service from us, we will process your information so that we can provide that service to you and bill you for it. When you apply for a job, you submit your PI which we use to process your application. This is called contract.
Secondly, we may want to use your PI for other reasons (for instance when you have given your consent for its use in a certain way and we decide to use it in another way, we will seek your consent. if that is the case, we will ask and obtain your consent. This will mean that you will sign a form or tick a box or talk to us on the phone. You are also entitled to withdraw your consent at any time. This is called consent.
Thirdly, as a business, we may assess our use of your PI and make a decision that our use is necessary and fair and does not remove your right to privacy. This is called legitimate business interest basis. It may be that we have a legitimate business interest to protect the intellectual property of our business (for instance protecting proprietary business information). Where we have legitimate business interest to use your PI, we will not seek your permission to use it.
Fourthly, some laws place obligations on us to share your PI for the security of the state for instance the Cyber crime Prohibition Prevention Act 2015, we may be required to share your PI to substantiate certain claims against money laundering or to prove we are complying with a certain regulation. When we have such legal obligation, we will not take permission from you to use your PI.
This policy sets out the option you have to object to certain ways we process your PI for instance, you always have a right to object to direct marketing from us or profiling. It also sets out the mechanism in place for you to exercise this right. We owe you a duty to take care of your PI and by this policy we state the measures we put in place to hold ourselves accountable for this information.
Who the Policy Affects?
It also applies to you if our relationship with you is indirect such as when you call our customer experience team to make inquiry about our services or products.
What not to Expect
Who we are?
Accessing and updating your Personal Information that we hold
You have a right to access and update the information we have about you. You can make this request in writing to firstname.lastname@example.org, email@example.com. We will ordinarily provide this information at no cost. When you make a request to know what information we hold of you, we will acknowledge your request, once received. We will authenticate your identity before providing that information. Let your request have a basis. Then give us a month to respond to your request. Do not ask information about another person. Once we acknowledge your request, do not continue to make the same request as this can be termed repetitive. We will do our best to give you answers regarding your PI that we hold but do not continue to make requests when we are working on your request or when we have given you a response based on our records. If we decide that your request has no basis or that it is repetitive or based on malice, we may refuse to give that information or charge you an administrative fee to give that information.
When we refuse to give you information or charge you for it, for any of the reasons stated above, we will still respond to you but our response will contain our reasons for refusing and your right to complain to the National Information Technology Development Agency (NITDA) or to apply to court. NITDA is the data protection authority in Nigeria. You can find NITDA’s address below.
Right to erasure
You have a right to request that your PI which we hold be erased from our systems. This right is only available when we are providing a consented service to you. If for instance, we ask for your permission to bring targeted advertisement to you and you agree, you can always opt-out of this service. If we get your permission to profile you, you may decide at any time to opt-out of this service. You can stop us by activating ‘do-not-disturb’.
There are other bases that we may be processing your PI that may not entitle you to exercise your right to erasure. If for instance we have an obligation under the law to hold your PI for audit and tax purposes or for the security of the state or for doing an act for the public, we will not be able to erase your PI.
Right to data portability
You can request that we transfer your data to another provider.
Right to stop processing
We aim to provide our products and service with respect to your PI and that of others, given this, when you ask us to delete your PI from our system this request may not immediately be carried out on our servers or our back-up systems. We may still keep some of the information to fulfill this request for instance we need to keep your email to ensure it is not on our marketing list. We may keep your phone number to confirm that it is not on our list. We may also keep it to prove compliance to legal requirements.
Remember that whatever request you make, may be declined if the rights of other persons will be breached by performing your request or the law precludes us from doing so. The one month we have within which to respond to you may be extended if we get too many requests. But whatever is the case, we will let you know.
When you are not satisfied with the way we process your data, or you have general inquiries about the way we use your PI, you can reach us on:
Address: 24 Chris Alli Crescent, 2nd Avenue Estate, Ikoyi, Lagos
Phone Number: 070068355483
E-mail: firstname.lastname@example.org, email@example.com
If you still feel unsatisfied after our resolution of your complaint, you have a right to complain to NITDA about your dissatisfaction.
You can write to NITDA on:
No 28, Port Harcourt Crescent, off Gimbiya Street P.M.B 564, Area 11, Garki Abuja, Nigeria
Mobile: +2348168401851, +2347052420189
What information we collect and what we use it for?
The PI we collect depends on the products and services we provide you and how you use them. Below we explained the varied ways we use your PI and the type of PI we collect in that occasion as follows:
- To provide products and services to you
We collect your PI when you register to purchase a product or a service from us or when you open an online account with us or download our app. We collect PI when you call a customer care agent to resolve communication issues for you. We also collect PI through the following social networking platforms:
- Facebook – https://www.facebook.com/ntelng
- LinkedIn – https://www.linkedin.com/company/10175549/
- Twitter – https://twitter.com/ntelng
- Instagram – https://www.instagram.com/ntelng/
When you do any of the above, we will:
- Record details of products and services you use or order.
- We will use your contact details to send you information about your purchase and tell you about any service that might affect your service.
- Update you on delivery, activation, connection or installation of your products and services.
- Enable you to create and login to an online account we manage.
- Filter any content you ask us to.
- Give information to another communications service provider if you are buying products from both of us.
- Charge you and make sure your payments reach us.
The kind of PI we collect for the above activities are:
- Your contact details and other identification information that confirms who you are and our communications with you. This may include your name, address, gender, phone number, date of birth, email address, password, other credentials such as security question and answers we have on your account.
- Your payment and financial information
- Your communications with us including emails, phone calls and web-chats
- To fulfill our legitimate business interest
In other to function efficiently and effectively as a business, we may have to use your PI. We may use it on this basis for the following reasons:
- To identify and let you know about the products and services available and which may be of interest to you.
- When your IP address is run on our IP transit and IP access services which we offer through our Sat- 3 technology.
To provide these services, we will:
- Create a profile about you to better understand you as a customer and tailor the messages we send to you. For instance, we might suggest more suitable products based on what you purchased.
- We can work with other business brands to show you relevant adverts.
- Share your PI within the organisation with our sales outlets or administration.
- Create aggregated information for further use (for instance to measure sales or measure staff retention)
We will use your PI to create aggregated information to:
- Make sure our network is working properly and continuously improve and develop our network, products and services for our customers.
- Create management reporting and corporate reporting, research and other analytics and to improve the business.
- To provide regulatory organisations like NITDA with aggregated information.
The personal information we use to generate aggregated data are:
- Your gender, address and date of birth.
- Information about what you buy from us, how you ordered it and how you paid for it for example data plan ordered online and paid monthly.
- Information from tags and cookies placed on you device.
- Details of products and services you have bought and how you use them like your voice call, data and fixed line service.
- To detect and prevent fraud
We will use your PI to detect and prevent fraud on our network. We monitor traffic over our network, trace nuisance or malicious calls and track malware and cyber-attacks. If we notice any irregularity, we may report this to law enforcement authorities. We do this to secure and protect our network and business and to comply with regulations.
- To meet our regulatory obligations
As communications service providers, we have a regulatory obligation to support law enforcement agencies to investigate crimes. If the police or EFCC or other security agencies make a request that we share your PI to help in solving crime or preventing crime, we will. The PI they will usually ask for are:
- Your contact details. That is your name, gender, date of birth, address, phone number, email address, biometric data.
- Your communications record with us such as calls, emails and web-chats.
- Your payment information.
Sharing your personal information
We have sales outlets – these are independent businesses that sell our products. When you want to purchase a product from our website, you may be redirected to one of these outlets. We use other organisations like Interswitch as a payment gateway. These organisations process payments for us. We have a legal obligation to file tax returns. We are required under the NDPR to file audit reports.
All ntel outlets have strict instructions not to sell your PI. Staffs are trained not to share your PI unlawfully.
Protection of your personal information and storage
The PI we collect from the website is stored on our data centre which is physically and logically secured. When you contact us through our social media handle, the PI you supply is stored on the server of those websites. These sites have processing agreement that bind them to implement appropriate technical and organisational measures to protect your PI. When we share your PI with government organisations, we check that they implement security measures to protect your PI.
We use physical and technical measures to secure your PI that we use. We ensure that all of our staff who handles your PI is regularly updated with information about the security of your PI.
The duration for the storage of your PI depends on what we need the information for. We will keep the following information:
- A summary of your bills for;
- Your contact details during the time that you use our services or buy our products;
- Details of any dispute;
- Detail of your employment for as long as necessary to fulfill our legal obligations.
We only keep information that is necessary to carry-out the reasons why we process your PI. Once we realise the purpose for processing your PI, we delete it.