Data Protection Policy

This Data Protection Policy — in conjunction with our Privacy Policy — expresses Termii’s (meaning Termii Webtech Limited or Termii Inc) pledge and commitment to treating the information of customers, stakeholders, partners and other interested parties with the utmost care and confidentiality, in accordance with the Nigeria Data Protection Regulations (NDPR), the General Data Protection Regulation (GDPR), and the laws of each jurisdiction whose data subjects we process.

With the provisions of this policy and our Privacy Policy, we acknowledge that we gather, store and handle data fairly, transparently, and with the utmost duty of care and respect towards individual rights.

1. Scope

As part of Termii’s operation, we often obtain and process information including names, addresses, phone numbers and email addresses. We collect this information securely, transparently and only with your full cooperation and knowledge. To ensure its protection, we apply the following rules:

• Use data for lawful purposes only.
• Protect it against any unauthorized or illegal access.
• Share it with third parties only to provide services.

To exercise the provisions of data protection regulations and show our commitment to compliance, we:

• 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 and access authorization.

2. How we obtain your personal data

We obtain your personal data when you use our service through the registration process. In signing up, we request data such as your name, phone number, address, email, company name, designation and country.

When funding your wallet through a third-party source, you will be directed to our payment institution’s platform to input your card details. Data at this stage is not stored on the Termii platform, but with the third party.

Likewise, while using our services you may be required to fill in your details and/or your customers’ details when using our Phonebook, Teams, Group or Direct SMS services — and when interacting with customer service, you may be asked for additional personal data so we can serve you properly.

3. Personal data usage

We use the personal data provided to us to process and deliver our services, to notify you of the status of those services, and to send marketing or campaign material you have opted in to receive.

4. Sharing your personal data

Termii does not sell or trade customer personal data to anyone. We only use it to render our services to you.

We may share your data — such as your name, phone number and email address — with partners or suppliers to provide services to you, with companies we engage to further your transaction, or when directing you to a third-party website providing services directly and/or on our behalf.

The privacy policies of these third-party sites may differ from our own and will govern any transactions and services performed on those sites. Termii and such companies are each independent data controllers, not joint controllers — you are advised to read and consent to their data protection and privacy policies.

As an organization offering services in different regions, we may need to transfer your personal data to our service providers, affiliates or contractors in various jurisdictions. In such cases, we ensure adequate safeguards and measures are in place so your data remains protected.

5. Securing customer personal data

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

6. Customer compliance

As a Termii customer, it is your responsibility to comply — and continue to comply — with applicable data protection laws and regulations in your use of our services, including the right to transfer, share and receive the consent of the data subjects whose data you share with us. By using our service, you agree that:

• You are complying, and will continue to comply, with applicable data protection laws and regulations for all data processed through your use of our service.
• You indemnify Termii of any and all liabilities, claims, legal actions, losses and damages resulting from data violations or your breach of 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.
• You shall provide Termii, insofar as possible and at Termii’s written request, with all information required to comply with statutory obligations under applicable data protection law — including security of processing, personal data breach notification, data protection impact assessments, and prior consultations with supervisory authorities.

7. Your choices and rights

You have the reserved right to decline requests for your personal data from Termii or its authorized representatives, and the right to withdraw consent given to this policy and our Privacy Policy. Contact us at company@termii.com to exercise any of your rights — note that certain services, or all services, may become unavailable to you as a result.

International standard privacy compliance

Termii is established, with offices, in more than one jurisdiction, and we provide services across many more. Our approach to data policy follows international standards covering the specific data protection requirements of each region.

• EEA & UK — the legal basis for collecting and using your personal data is as stipulated above. In certain circumstances we may also have a legal obligation to collect personal data when required by a government or regulatory enforcement agency.
• California — we recognize the California consumer access and deletion rights. You can contact us at any time to request information about your personal data or to have it deleted; once we verify your authority to make the request, we will act on it as swiftly as possible.
• Everywhere else — our policy is broad enough to cover and safeguard your interests regardless of where you are or reside. We offer high standards of privacy and data protection to all our customers.

8. Changes to our policies

We reserve the right to change these policies at any time at our discretion. If we change any of our policies, we will post those changes here and anywhere else we deem appropriate. If we make material changes, we will notify you here, by email, or with a notice on our home page.