Privacy and Cookie Policy
MTN Nigeria Communications PLC (“MTN”), a public limited liability company, incorporated in
the Federal Republic of Nigeria with registration number 395010 and its principal office at
MTN Plaza, Falomo Roundabout, Awolowo Road, Ikoyi, Lagos, respects the privacy of our
Customers’ Personal Information which should be protected through the use and interaction
with www.shop.mtn.ng, www.mtnonline.com and all associated websites, mobile applications,
products and services.
We have prepared this MTN Customer Privacy Notice (this “Privacy Notice or “Notice”) to
notify You of the type of Personal Information we collect from You, Our Customers and/or
Users; how We will treat that Personal Information; and the circumstances under which We
will share it with third parties.
| The following key terms should be read in conjunction with this Notice: | Definition |
|---|---|
| Consent | Freely given indication of the Customer’s wishes or a clear affirmative action signifying Customer’s or User’s agreement to the processing of Personal Data relating to him or her. |
| Data Subject | The person (natural or juristic) to whom Personal Information relates. In this case, the Customer. |
| Customer | Customer A customer is a person (individual or organization) who enters into a contract by subscribing to MTN or any it’s Affiliates’ Services or Products, for use (as part of an integrated solution provided by MTN or any MTN Affiliate). |
| Personal Information | Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. This includes, but is not limited to, details such as Your name, phone number, address, age, curriculum vitae, marital status, gender, health details, location information, online identifier, the personal opinions, views or preferences of the person; company’s registered name, registration number, Director’s names, ID numbers, addresses and other company details which could include: financial information and banking details and registered or unregistered identification or proprietary marks etc. |
| Processing / Process of Personal Information | Processing / Process of Personal Information Any operation or activity or
any set of operations, whether by automatic means, concerning Your Personal
Information, including— (a) the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use; (b) dissemination by means of transmission, distribution or making available in any other form; or (c) merging, linking, as well as restriction, degradation, erasure or destruction of Personal Information. |
| Operator | A third-party who is processing Personal Information for MTN in terms of a contract or mandate, without coming under the direct authority of that party. |
| Organisations | Organisations This means other entities such as a service provider, whether it is an affiliate or a supplier, to perform activities, services, functions, or processes on an ongoing basis that would normally have been undertaken by MTN itself. |
| Sensitive Personal Information | Information relating to Your biometric details, race, pregnancy, marital status, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of that person. |
| “You”, “Your” | the Customer |
| “Us”, “We”, “Our” MTN | MTN |
| User | A user is a person (individual or organisation) who uses any of MTN channels, which are not limited to MTN websites; mobile applications; Unstructured Supplementary Service Data (USSD) and Short Message Service (SMS); and other products and services. |
| MTN Data | MTN Personal Information, Personal Information of its affiliates, customers, employees, agents, representatives, contractors and professional advisors. |
Customers who are natural persons must be 18 years or older. If You are under 18 years, you may only use MTN websites, mobile applications, products and services with the assistance of a parent or guardian who has provided consent for You.
This Notice applies to:
- all Customers and/or users who are natural persons; and
- all Customers and/or users who are organisations.
- all MTN suppliers, partners and service providers.
- all MTN Foundation applicants, recipients, and partners.
- All Retail agents.
While You are making use of any MTN website, mobile applications, MTN automatically collects certain personal or company information such as Your IP address; browser type; operating system; mobile carrier; Your Internet Service Provider (ISP), Uniform Resource Locators (URLs) of sites from which You arrive or leave the MTN website; and mobile applications and sites that have embedded MTN platform technology. Through cookies and other technologies, We can recognise You as an existing or registered user of the MTN website and/or mobile application and are able to better serve You as a result.
Cookies
A cookie is generally a tiny data file that resides on Your computer, mobile phone, or other devices, and allows MTN to recognise You as a user when You return to the MTN online store website using the same computer and web browser. There are different types of cookies. Here are two examples:
A “persistent” cookie – this cookie is set once You have logged on to a website. The next time You visit the website, the persistent cookie will allow the website to recognise You as an existing user or registered user, so You will not need to log in before using the services. However, if You wish to access or change any of Your payment information (like a debit or credit card number) or Your registered information, You must log in securely again with Your password, even if Your computer contains a persistent cookie.
A “session” cookie – this cookie is used to identify a visit to a website. Session cookies expire after a short time or when You close Your web browser.
You can remove or block cookies using the settings in Your browser, but in some cases doing so may impact Your ability to use the website.
By accepting to this, You are accepting the terms of this Privacy Notice and consenting to the processing of Your personal or company information and accepting the practices described in this Notice.
To provide You, Our Customers and/or user, with the best online services, mobile applications, USSD and SMS products and services, MTN will use Your Personal Information to:
- Process the goods and services You have bought from Us, and keep You updated with Your order progress.
- Carry out a credit check if You are applying for a contract for services, and to assess Your application.
- Provide the relevant service or product to You. This includes other services not included in Your agreement with Us, and services that use information about where You are when using Your mobile equipment (location information) and to contact You with messages about changes to the service or product.
- Bill You for using Our products or services.
- Protect Our network and manage the volume of calls, texts, online traffic and other use of Our network. For example, We identify peak periods of use, so We can ensure the network functions optimally during those times.
- Understand how You use Our network, products and services. That way, We can develop more interesting and relevant products and services, as well as personalise the products and services We offer You.
- Carry out research and statistical analysis to monitor how Customers and/or users’ use Our network, products and services on an anonymous or personal basis.
- Review Your application, participation or eligibility in respect of any form of donation, project or program under MTN Foundation.
- Conduct market research and perform statistical analyses of Our Customers and/or users’ behaviour. By being aware of Our Customer’s and/or User’s interest in and use of the various areas of the MTN websites, mobile applications, USSD and SMS products and services for MTN to better serve its Customers and/or Users.
- Share information across MTN’s different business units for processing to serve MTN’s Customers and/or users more efficiently such as, but not limited to, Credit Vetting Process, Direct Marketing Process and Customer Loyalty Processes.
- Share information with MTN third parties within Our operations and Value Added Service Providers where We have an underlying contractual relationship to provide the service to You, including those third parties to whom You have subscribed for their services and consented to Our provision of Your Personal Information to them.
- Prevent and detect fraud, information security and privacy incidents and other crimes, recover debts or trace those who owe Us money.
- Send You promotional materials or details by SMS, e-mail, post or electronic communication provided You have given Your consent to receive such promotional materials from MTN.
- Let You know about other companies’ products and services (including offers and discounts We have specially negotiated for Our customers) that We think may interest You if You have chosen to receive this information.
- Contact You in the event of a query and respond to any questions or concerns You may have about using Our network, products or services.
- In any circumstance prescribed by law including but not limited to biometrics for SIM registration, investigation of criminal activities, directives from law enforcement etc.
- Provide up to date service delivery as regards the services subscribed to and/or made available by MTN to its Customers.
- for occupational health administration; work management; business travel; corporate security; organisational charts; archiving emails for disaster recovery purposes, legal and regulatory reporting obligations; and any other legitimate business interests;
- Where Your Personal Information is required other than in respect of the aforementioned, MTN shall notify You of such other purpose for which Your Personal Information is required to enable You to provide Your consent.
Maintaining the security of Your Personal Information is important to MTN. Reasonable security safeguards have been implemented to protect Your Personal Information. MTN uses various methods to protect Your information such as:
- Encryption methods when transmitting payment information, such as Your credit card information. An icon resembling a padlock is displayed on the bottom of most Internet browser windows during encrypted transactions.
- Access to Your Personal Information on MTN websites, mobile applications, USSD and SMS products and services will be encrypted and/or password-protected.
- Sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between Your web browser and the MTN website and mobile applications.
- To protect any data, You store on Our servers, MTN regularly audits its systems for possible vulnerabilities and attacks.
- MTN maintains an Information Security Programme internally to ensure that Your Personal Information is protected against unauthorised access, accidental loss or destruction.
MTN will share Your Personal Information to third parties only where it is necessary to deliver services You and in compliance with a lawful order or request without recourse to the Customer. Disclosure in the former instance shall be made with the Customer and/or user’s consent;
There will be circumstances where We are obliged to disclose Your information by law and are prohibited from informing You when we have received a request for Your Personal Information in relation to any suspected or alleged criminal activity.In addition, companies employed by MTN to perform certain functions (“Third Parties”) may be assessed to ensure that they handle Our Customer and/or user information securely. Some of MTN Third Parties perform the following functions for MTN:
- Receiving payments, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing market assistance, providing search results and links (including paid listings and links), processing credit card payment, and providing customer service.
- Approved online service on MTN’s websites, products and services.
These Third Parties have access to Personal Information needed to perform their functions and for purposes clearly defined by MTN.
10.1 Erasing your information
You have the right to request that MTN erase your Personal Data if it is no
longer
valid or necessary for the purposes for which it was collected or if it is
incomplete or inaccurate.
You have the right to receive your Personal Data in a commonly used and
machine-readable format and the right to transmit these data to another Data
Controller when the processing is based on (explicit) consent or when the
processing is necessary for the performance of a contract.
10.2 Accessing and Changing Your Information
You can review the information You provide to Us and make any desired changes to the information You have provided. Please be aware that even after Your request for a change is processed, MTN may, for a time, retain residual information about You in its backup and/or archival copies of its database.
10.3 Direct Marketing
You have the right to choose whether You receive marketing material or not. By accepting using Our products and services, You are also agreeing to MTN sending You marketing material on related services, products and offerings provided from MTN from time to time. If You change Your mind at any time, You are always able to opt-out.
We do comply with applicable provisions of the Nigerian Communications Commission’s Guidelines and relevant Consumer Protection regulations on direct marketing.
10.4 Deletion or destruction of Your Information and Period of Retention
10.4.1 You may request that we delete and destroy any of Your Personal Information provided that Your relationship with MTN has been appropriately terminated.
10.4.2 MTN will, however, retain and use Your Personal Information in accordance with applicable laws for retention of data, for as long as is necessary to provide You with Our services and comply with legal and business obligations, resolution of disputes and enforcement of this Notice among others.
10.5 Transfer and storage of Personal Information across borders
- You understand that MTN may be required to host, process, transfer and store Your Personal Information in other countries for business purposes which could include giving effect to a third-party contract for Your benefit or Your protection.
- MTN shall ensure that the countries have adequate data protection laws, corporate security policies, procedures and standards to adequately protect Your Personal Information as prescribed by Nigerian Data Protection Regulation.
- Your Personal Information shall be stored in Oracle Advanced Security Transparent Data Encryption format using Generally Accepted International Security Standards (ISO).
- Your Personal Information shall be subject to the Nigerian Data Protection Regulation 2019 (as may be amended from time to time) and any other applicable Data Protection Regulation.
10.6 Right to withdraw consent
You have a right to withdraw Your consent at any time without affecting the lawfulness of Your information received and processed by MTN in line any legal obligation or prior to Your withdrawal of consent.
10. 7 Reporting incidents
In the event of a privacy breach, MTN shall report such breach to the relevant authority and if necessary, affected individuals of personal data breach (where the personal data breach will likely result in high risks to the freedoms and rights of the data subject) within reasonable time of being aware of the breach. MTN shall take steps to investigate and recover personal data. MTN will also ensure that controls are enhanced to prevent a re-occurrence of the breach. You have a right to lodge a complaint before an appropriate authority for any breach of Your rights.
Kindly notify Us:As a Customer and/or user, there are certain obligations expected from You. Some of these obligations are imposed by applicable law and regulations, and others have become commonplace for MTN:
• You must always abide by the terms of this Notice and any agreement or consent relating to MTN products and services that You have subscribed to. This includes respecting all intellectual property rights that may belong to Third Parties (such as trademarks or photographs).• You must not download or otherwise disseminate any information that may be deemed to be injurious, violent, offensive, racist or xenophobic, discriminates against people on the basis of gender and sexual orientation threatens the rights and safety of others, or which may otherwise violate the purpose and spirit of MTN and its community of users on MTN websites and/or mobile applications.
• You must not provide MTN with information that You believe might be false or misleading.
• You must keep Your username and password confidential and not share it with others.
• Promptly notify MTN at the Contact Details indicated below, where You wish to exercise any of Your rights with respect to Your Personal Information.
MTN may, at any time, change its Privacy policy and this Privacy Notice by posting the
amended version on www.mtnonline.com. Unless otherwise stated, the current version will
apply each time You access this website.
Address: MTN Nigeria Communications PLC
Email address: DPONigeria@mtn.com