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Our Policies
Data privacy and protection policy
Emerging Markets Telecommunication Services Limited (9mobile) Data privacy & Protection Policy
1 INTRODUCTION
As part of our operations, Emerging Markets Telecommunication Services Limited (“9mobile” or “the Company”) collects and processes certain types of information (such as name, telephone numbers, address, etc.) of individuals that makes them easily identifiable. These individuals include current, past and prospective employees, merchants, suppliers/vendors, cus-tomers of merchants and other individuals whom 9mobile communicates or deals with, jointly and/or severally (“Data Subjects”).
Maintaining the Data Subject’s trust and confidence requires that Data Subjects do not suffer negative consequences/effects as a result of providing 9mobile with their Personal Data. To this end, 9mobile is firmly committed to complying with applicable data protection laws, regulations, rules, and principles to ensure security of Personal Data handled by the Company. This Data Privacy & Protection Policy (“Policy”) describes the minimum standards that must be strictly adhered to regarding the collection, use and disclosure of Personal Data and indicates that 9mobile is dedicated to processing the Personal Data it receives or processes with absolute confidentiality and security.
This Policy applies to all forms of systems, operations and processes within the 9mobile environment that involve the collection, storage, use, transmission and disposal of Personal Data.
Failure to comply with the data protection rules and guiding principles set out in the Nigeria Data Protection Regulation, 2019 (NDPR), the Nigeria Data Protection Act, 2023 (NDPA) as well as those set out in this Policy is a material violation of 9mobile’s policies and may result in disciplinary action as required, including suspension or termination of employment or business relationship.
2 SCOPE
This Policy applies to customers, all employees of 9mobile, as well as to any external business partners (such as merchants, suppliers, contractors, vendors and other service providers) who receive, send, collect, access, or process Personal Data in any way on behalf of 9mobile, including processing wholly or partly by automated means. This Policy also applies to third party Data Processors who process Personal Data received from 9mobile.
3 GENERAL PRINCIPLES OF PROCESSING DATA
9mobile is committed to maintaining the principles in the NDPR and NDPA regarding the processing of Personal Data.
To demonstrate this commitment as well as our aim of creating a positive privacy culture within 9mobile, 9mobile adheres to the following basic principles relating to the processing of Personal Data:
3.1 Lawfulness, Fairness and Transparency
Fairness and Transparency Personal Data must be processed lawfully, fairly and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of 9mobile must be in accordance with the specific, legitimate and lawful purpose consented to by the Data Subject, save where the processing is otherwise allowed by law or within other legal grounds recognized in the NDPA and NDPA.
3.2 Data Accuracy
Personal Data must be accurate and kept up to date. In this regard, 9mobile:
(a) shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to the Data Subject.
(b) make efforts to keep Personal Data updated where reasonable and applicable; and
(c) make timely efforts to correct or erase Personal Data when inaccuracies are discovered.
3.3 Purpose Limitation
9mobile collects Personal Data only for the purposes identified in the appropriate 9mobile Privacy Notice provided to the Data Subject and for which Consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except a new Consent is obtained.
The purposes for which 9mobile will use your personal data includes:
a) For the provision of services to you. For example, when you purchase any of our products or services, we will use your personal data to process your order.
b) For customer care and billing. When you use our products or services, we will use your personal information to bill you and to respond to enquiries and concerns that you may have about our products and services.
c) Customer service messages. We will use your personal data to keep you updated with the latest information or changes about our products and services.
d) For marketing purposes. In order to serve you better, will use your personal data to market our products and services to you.
e) Fraud prevention and security. We will process your personal and traffic data in order to protect you against and detect fraud, to protect and detect misuse or damage to our networks.
f) Managing our networks and understanding network usage. We do this to manage the volume of calls and to understand how you use our networks, products and services.
3.4 Data Minimization
3.4.1
9mobile limits Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed.
3.4.2
9mobile will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized data must be used.
3.5 Integrity and Confidentiality
3.5.1
9mobile shall establish adequate controls in order to protect the integrity and confidentiality of Personal Data, both in digital and physical format and to prevent personal data from being accidentally or deliberately compromised.
3.5.2
Personal data of Data Subjects must be protected from unauthorized viewing or access and from unauthorized changes to ensure that it is reliable and correct.
3.5.3
Any personal data processing undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties is un-authorized.
3.5.4
Employees may have access to Personal Data only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Data for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.
3.5.5
Human Resources Department must inform employees at the start of the employment relationship about the obligation to maintain personal data privacy. This obligation shall remain in force even after employment has ended.
3.6 Personal Data Retention
3.6.1
All personal information shall be retained, stored and destroyed by 9mobile in line with 9mobile’s Document retention policy, legislative and regulatory guidelines. For all Personal Data and records obtained, used and stored within the Company, 9mobile shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.
3.6.2
To the extent permitted by applicable laws and without prejudice to 9mobile’s Document Retention Policy, the length of storage of Personal Data shall, amongst other things, be determined by:
(a) the contract terms agreed between 9mobile and the Data Subject or if it is needed for the purpose for which it was obtained; or
(b) whether the transaction or relationship has statutory implication or a required retention period; or
(c) whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require 9mobile to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
(d) whether 9mobile has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
Notwithstanding the foregoing and pursuant to the NDPR and NDPA, 9mobile shall be entitled to retain and process Personal Data for archiving, scientific research, historical research or statistical purposes for public interest.
3.6.3
9mobile would forthwith delete Personal Data in 9mobile’s possession where such Personal Data is no longer required by 9mobile or in line with 9mobile’s Retention Policy, provided no law or regulation being in force requires 9mobile to retain such Personal Data.
3.7 Accountability
3.7.1
9mobile demonstrates accountability in line with the NDPR and NDPA obligations by monitoring and continuously improving data privacy practices within 9mobile.
3.7.2
Any individual or employee who breaches this Policy may be subject to internal disciplinary action (up to and including termination of their employment); and may also face civil or criminal liability if their action violates the law.
4 DATA PRIVACY NOTICE
4.1
9mobile considers Personal Data as confidential and as such must be adequately protected from unauthorized use and/or disclosure. 9mobile will ensure that the Data Subjects are provided with adequate information regarding the use of their Personal Data as well as acquire their respective Consent, where necessary.
4.2
9mobile shall display a simple and conspicuous notice (Privacy Notice) on any medium through which Personal Data is being collected or processed. The following information must be considered for inclusion in the Privacy Notice, as appropriate in distinct circumstances in order to ensure fair and transparent processing:
a) Description of collectible Personal Data;
b) Purposes for which Personal Data is collected, used and disclosed;
c) What constitutes Data Subject’s Consent;
d) Purpose for the collection of Personal Data;
e) The technical methods used to collect and store the information;
f) Available remedies in the event of violation of the Policy and the timeframe for remedy; and
g) Adequate information in order to initiate the process of exercising their privacy rights, such as access to, rectification and deletion of Personal Data.
5. LEGAL GROUNDS FOR PROCESSING OF PERSONAL DATA
The personal data we collect from our customers and how we collect it depends on the services that our customers subscribe to, how they use our services and how they interact or interface with us. This also applies to persons who are not customers of 9mobile but have interacted with 9mobile. We may also obtain your personal data from a third party with permission to share it with us.
Please note that we only process your personal data based on the grounds set out in the NDPR and NDPA. Accordingly, in line with the provisions of the NDPR and NDPA, processing of Personal Data by 9mobile shall be lawful if at least one of the following applies:
a) where you give us consent to the processing of your Personal Data for one or more specific purposes. You are at liberty to withdraw the consent and 9mobile will cease to process your personal data where there is no other basis to do so.
b) Where the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which 9mobile is subject;
d) processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
e) processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in 9mobile.
f) processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data..
5.1. We collect your personal data when you do any of the following:
a) Buy or use any of our products and services;
b) Use our network or other 9mobile products and services;
c) Register for a specific product or service;
d) Fill in your information on our KYC registration form, self-service applications (including the ig9ite app), social media platforms, SIM Swap Forms, MNP Forms;
e) Visit or browse our website;
f) Have given permission to other companies to share information about you;
g) Where your information is publicly available;
h) Are the customers of a business we acquire or;
i) Take part in a competition, prize draw or survey.
j) We also keep records when you use conduct an activity on your mobile phone using our network. This includes the number you dialled, the length, date and time of that call, and your approximate location (when you are browsing). This information is kept in the Call Data Record (CDR). We also get your URL. Personal data we have about our customers, where applicable includes: name, phone number, address, sex, photograph, ID card number, fingerprint, and signature.
6. CONSENT
Where processing of Personal Data is based on consent, 9mobile shall obtain the requisite consent of Data Subjects at the time of collection of Personal Data. In this regard, 9mobile will ensure: