This Data Protection Policy in conjunction with our Privacy Policy (https://termii.com/privacy) expressed TERMII which hereinafter may be referred to as (“our” “we” or “the Company”) assurance and commitment to treating the information of customers, stakeholders, partners, and other interested parties (“You or Your”) with the utmost care and confidentiality in accordance to the Nigeria Data Protection Regulations (NDPR), General Data Protection Regulation (GDPR) and each jurisdiction of data subject whose data we process.
With the provisions of this data protection policy and our privacy policy, we acknowledge that we gather, store, and handle data fairly, transparently, and with utmost duty of care and respect towards individual rights.

1.0 Scope
As part of Termii’s operation, we often obtain and process information which includes names, addresses, phone numbers, Emails, etc. We collect this information securely and transparently and only with your full cooperation and knowledge.
To ensure the protection of this information, we apply the following rules.
        • Use for lawful purposes only
      • Protect against any unauthorized and illegal access.
     • Only share with the third party to provide services

To exercise the provisions of data protection regulations and show our commitment to ensure our compliant and adhere to the provisions, We:
        • Restrict and monitor access to sensitive data
        • Restrict and monitor access to sensitive data
        • Train employees in online privacy and security measures
        • Build secure networks to protect online data from cyberattacks
        • Establish clear procedures for reporting privacy breaches or data misuse
      • Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization, etc.)

2.0 How We Obtain Your Personal Data
We obtain your personal data when you use our service through the registration process. In the process of signing up, we request data such as name, phone number, address, Email, Company name, Designation, and Country. Through a third-party source, in the process of funding your wallet, you will be directed to our payment institution platform where you will be required to input your card detail for such funding. Please note that the data at this stage is not stored on the Termii platform but on the third party. Likewise, while using our services, you may be required to fill in your details and/or your customer’s details during the use of our Phone book, Teams, Group, or Direct SMS services. In addition, when interacting with our customer service, you may be required to provide us with more personal data to provide quality services to you.

3.0 Personal Data Usage
Ways in which we used the personal data provided to us include processing or delivering our services, notifying you of the status of the services, and sending marketing or campaign affiliates to which you opt-in.

4.0 Sharing Your Personal Data
Notwithstanding the provision of this clause, Termii does not sell nor trade customer personal data to anyone. We only use it to render our services to you.

We may share your data with our partners or suppliers to provide services to you. Such data may include your name, phone number, and Email address. We may also share your data with companies or organizations that we engage to provide services to us for the furtherance of your transaction or direct you to a third-party website that may provide services for you directly and/or on our behalf. An example is the funding of your wallet stage.
THE PRIVACY POLICIES OF THESE THIRD-PARTY SITES MAY BE DIFFERENT FROM OUR DATA PROTECTION AND PRIVACY POLICY. THUS, WILL GOVERN ANY TRANSACTIONS AND SERVICES PERFORMED ON THAT SITE. TERMII AND SUCH COMPANIES ARE EACH INDEPENDENT DATA CONTROLLERS AND NOT JOINT DATA CONTROLLERS. Hence, you are advised to read and consent to such third-party site data protection and privacy policy.

4.1 As an organization that offers our services in different regions, we may need to transfer your personal data to our service providers, affiliates, or contractors in various jurisdictions to provide our services to you. In such cases, we ensure adequate safeguards and measures are put in place for your data to remain protected

5.0 Means of Securing Customer Personal Data

We secure your data by using a database with limited access and a secure server that encrypts all the data we collect. Hence protecting it from unauthorized third parties. We as well use a firewall to prevent access to information on our system.

6.0 Customers Compliance

It is the responsibility of you as Termii customer to ensure that you comply and continue to comply with Applicable Data Protection Laws and Regulations in your use of our services and in processing personal data. In addition, you will be responsible for the right to transfer, share and receive the consent of data subjects that you share with us to provide our service or usage of our service.
By using our service, you hereby undersigned and agree as follows:
      • You are complying and will continue to comply with applicable Data Protection Laws and Regulations that you processed through your use of our service.
      • Hereby indemnify Termii of any and/or all liabilities, claims, legal actions, losses, and damages as a result of data violation and/or you breaching any data protection laws and regulations.
      • You will not intentionally collect or process any special categories of Personal Data unless Termii includes such types of data in the content submitted to you
      • Taking into account the nature of processing and the information available to you, You shall provide Termii, insofar as this is possible and at Termii’s written request, with all information required for Termii to comply with statutory obligations under Applicable Data Protection Law (in particular, the obligations necessary to ensure the Termii’s compliance with security of processing, personal data breach notification, data protection impact assessment, and prior consultations with supervisory authorities), and will assist Termii, insofar as reasonable, in meeting these statutory obligations.

7.0 Customers’ Choices and Rights
You have the reserved right to decline the request of providing your personal when requested by Termii or Termii’s authorized representatives. You also have the right to withdraw given consent to our data protection policy and privacy policy Please contact us at dataprotection@termii.com if you wish to exercise any of your rights. It is however noteworthy to mention that certain services or all services may be unavailable to you.

INTERNATIONAL STANDARD PRIVACY COMPLIANCE AT TERMII
Termii is a company established and with offices in more than one jurisdiction thus, we recognize that we have customers and provide our services to customers in different jurisdictions. Hence our approach to data policies is the international standard that covers specific data protection requirements from regions. Therefore, regardless of where you are located, we are committed to abiding by all applicable data protection regulations.

European Economic Area (EEA) and United Kingdom (UK)
If you are from a region such as Europe or the UK where there is a requirement of the legal basis for processing your personal data, the basis for collecting and using your personal data is as explicitly stipulated above. However, in certain circumstances, we may also have a legal obligation to collect certain personal data from you when required or mandated by a government or regulatory enforcement agency. Should you require more information and/or clarification regarding the basis on which we collect and use your personal data, do not hesitate to contact us at dataprotection@termii.com

UNITED STATES
If you are from the United States, we recognize the California Consumer Access and Deletion Rights. Thus, as provided above, you can contact us at any time to request any information regarding your personal data and as well for your personal data to be deleted. Once we verified that you are authorized to make the request, we will inform you of the limitation of service it may bring to you and ensure your request is carried out as swiftly as possible.

OTHER REGION
If you are in a region that is not specifically mentioned here, you can rest assured that our policy is broad and extensive enough to cover and safeguard your interest regardless of where you are or reside. We offer high standards of privacy and data protection to all our customers and respect individual citizenship data protection regulation requirements. Some regions are only outlined based on the specific requirement from those regions for us to include in our privacy and data protection policy.

Changes in our Policies
We reserve the right to change these policies at any time subject to our discretion. If we choose to change any of our policies, we will post those changes to this here and any other places we deem appropriate so that you are aware. If we make material changes to any of these policies, we will notify you here, by email, or using a notice on our home page.