TELCABLES PRIVACY POLICY

1. Introduction

This Privacy Policy (Policy) and any other document referred to sets out the basis on which any Personal Data Telcables Nigeria Limited (“Telcables”, “we”, “us”, “our”) collect from “You” (“Customer” or “User” of this website), or that you provide to us, will be processed by us. It applies to our website and all database, applications, services, tools and physical contact with us, regardless of how you access or use them.

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. By clicking on the “accept” button, you are accepting and consenting to the practices described in this Policy. If you have any comments on this Policy, please email them to: geral.ng@telcables.net

2. Who We Are Please visit our corporate website address here: www.telcables.ng

3. Collection of Your Personal Data

We will collect and process the following Personal Data about you:

3.1. Personal Data and content you provide: We collect the content, communication and other Personal Data you provide when you use our services, including when you fill forms or surveys or sign up for an account, or by corresponding with us via phone, e-mail or otherwise. The Personal Data you give us may include your name, address, e-mail address, phone number, personal description and photograph.

3.2. Personal Data we collect about you: With regard to each of your visits to our website or the use of our products, we will automatically collect the following information:

a. Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type, time zone setting, browser plug-in types and versions, operating system and platform;

b. Information about your use of our website and mobile application (including date and time), details of transactions you carry out, interaction information, record of any correspondence between us and any phone number used to call our customer/client service number;

c. Information about your visit(s) from your IP address, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.

3.3. We may collect your Personal Data when you send your CV or apply for a job application and employment.

3.4. We will also tell you for what purpose we will share and combine your Personal Data [subject to clause 7 below]. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive any Personal Data about you from them and the purposes for which we intend to use that Personal Data, where such purpose is different from which you have consented under this Policy and there is material difference in the terms contained here and the conditions applicable to such data collected, we will request your consent to same.

4. How We Use Your Personal Data

4.1. Personal data collected helps us to personalize our products according to each Data Subject’s wish and preference.

4.2. We use your Personal Data held about you in the following ways, that is, to:

a. tailor the content we display to you;

b. carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us;

c. provide you with information about other goods and services we provide that are similar to those that you have already purchased or enquired about;

d. notify you about changes to our service;

e. ensure that content from our product is presented in the most effective manner for you and for your computer;

f. administer our product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

g. improve our product to ensure that content is presented in the most effective manner for you and for your device;

h. allow you to participate in interactive features of our service, when you choose to do so;

i. measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

j. make suggestions and recommendations to you and other users of our product about goods or services that may interest you or them.

5. Marketing

We will use Personal Data provided by you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer/client, we will only contact you by electronic means (call, e-mail or SMS) with information about goods and services similar to those, which were the subject of a previous sale or negotiation of a sale to you. If you are a new customer/client, and where we permit selected third parties to use your Personal Data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your Personal Data in this way, or to pass your details on to third parties for marketing purposes, you may unsubscribe from promotional emails via a link provided in each marketing message.

6. Security

We adopt robust technologies and security policies to ensure the Personal Data we hold about you is suitably protected. We take steps to protect your Personal Data from unauthorized access and against unlawful processing, accidental loss, destruction and damage. To prevent unauthorised access to your information, we have strong controls and security safeguards at the technical and operational levels. These include but not limited to:

Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

If you know or suspect that anyone other than you become aware of your security details, you must promptly notify us at geral.ng@telcables.net

7. Disclosure and Sharing of your Personal Data

7.1. We will usually not share your Personal Data with other third parties without your consent. You agree that we have the right to share your Personal Data with:

a. any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined under the Nigerian Companies and Allied Matters Act 2020;

b. our authorized employees only for the purpose of resolving issues associated with the use of our services;

c. selected third parties including: business partners, suppliers or sub-contractors for the performance of any contract we enter with them; and advertisers and advertising networks that require the Personal Data to select and serve relevant adverts to you and others.

d. analytics and search engine providers that assist us in the improvement and optimisation of our corporate and products websites.

7.2. We may share your Personal Data without your consent in any of the following situations:

a. if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our, our clients and others’ rights, property, or safety;

b. where we are requested to provide your Personal Data by authorized third parties or regulatory/governmental agencies investigating illegal activities;

c. If we sell or buy any business or assets, in which case, that will require that we disclose your Personal Data to the prospective seller or buyer of such business or assets;

d. if we or substantially all our assets are acquired by a third party, in which case Personal Data and the information we hold about you forms part of the transferred assets;

e. we may hold events including seminars and conferences which are sponsored by third parties or have third party speakers. Where you register for one of these events, we may share your Personal Data with those third parties;

f. we use third party payment processing services when you make payment through our website. We do not have access to any credit card or financial data processed by the third party.

8. Links to Other Websites and Premises

Certain transaction processing channels may require links to other websites or organisations other than ours. Please note that the Telcables is not responsible and has no control over websites outside its domain. We do not monitor or review the content of other party’s websites which are linked from our website or media platforms.

Please be aware that we are not responsible for the privacy practices, or content of these sites.

We encourage our users to be aware of when they leave our site, and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them.

9. Where we Store your Data

The Personal Data that we collect from you will be transferred to, and stored at, a destination outside Nigeria. We have identified all our storage locations of your Personal Data which is part of the National Information Technology Development Agency’s Whitelist. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and the Nigeria Data Protection Act (NDPA) and relevant data protection regulations. Furthermore, all Personal Data you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password, which enables you to access the services on our website and mobile applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10. Retention of Information

10.1. Your Personal Data will not be retained for longer than is necessary for the purposes for which it was processed.

10.2. Your Personal Data will be stored as long as you have an active client account. If your account is closed, information will be deleted from the databases in line with our retention period, unless such Personal Data is required to be retained for accounting, dispute resolution or fraud prevention purposes.

10.3. Our retention period for the storage of personal data shall be 3 years after the last active use of the website.

11. Your Rights as a Data Subject

11.1. All individuals who are the subject of Personal Data held by Telcables have the following rights:

a. You have a right to consent to this Privacy Policy and to withdraw your consent at any time.

b. Right to objection or request for restriction;

c. Right to object to automated decision making;

d. Right to request rectification and modification of their data kept by Telcables;

e. Right to request for deletion of their data, except as restricted by law or Telcables’ statutory obligations;

f. Right to request the movement of data from Telcables to a Third Party; this is the right to the portability of data;

g. Right to request for and access their Personal Data collected and stored. Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format;

h. Right to information on their personal data collected and stored as provided under the NDPA;

i. Right to lodge a complaint about the handling of your Personal Data with the Nigeria Data Protection Commission (NDPC).

11.2. If you wish to exercise your rights, you may contact the office of our data protection and compliance officer at 3rd Floor, DUKKA, 42 Saka Tinubu Street, Victoria Island, Lagos, Nigeria.

12. Cookies

When you visit our website, we collect information automatically using tracking technologies, like cookies to analyse trends, administer the website, monitor how visitors navigate around the websites, and to gather demographic information about our user base as a whole. For more information about how we use cookies on our websites and how to manage your cookie preferences, please refer to our Cookie Policies here www.telcables.ng

13. Breach/Privacy Violation

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to the NDPC.

Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach. Where the confirmation of the risk to your rights and freedom occurred after seven days of such occurrence, we shall notify you immediately.

14. Changes to this Policy

We reserve the right to amend this Privacy Policy from time to time to reflect changing legal requirements or our processing practices. Such changes will be operative upon the date any updated version of our Privacy Policy is uploaded to our website.

15. Contact – Data Protection Officer

Telcables has appointed a Data Protection Officer(s) (DPO) responsible for overseeing our data protection strategy and its implementation to ensure compliance with the NDPA requirements. The DPO is knowledgeable in data privacy and protection principles and is familiar with the provisions of the NDPA.

The contact details of the Data Protection officer are as follows

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