Privacy Policy

1. Who we are:

This app (referred to as MySmile App) available for Android and IOS operating systems respectively, as well as Smile websites (www.smile.com.ng, www.smile.co.ug, ) are operated by Smile Telecoms Holding Ltd (“Smile”) including its subsidiaries in Nigeria (Smile Communications Nigeria Limited), Tanzania (Smile Communications Tanzania Limited), and Uganda (Smile Communication Uganda Limited) respectively.

References to “Smile”, “we”, “us”, “our” and “ours” in this Privacy Policy mean Smile.

The terms “you”, “your” and “yours” when used in this Privacy Policy mean any user of this App.

 

2. Purpose of this Privacy Policy:

We are committed to the privacy and confidentiality of information provided to us. This Privacy Policy provides information to help you understand how we collect, use and share your personal information and our privacy practices with regard to any personal information collected by us from you directly and/or through the MySmile App, Smile websites or the use of our products and services.

Personal information means information which identifies you, and includes information such as your name, email address, telephone number, MSISDN, SmileNumber, and password, as well as any other personal data collected.

By using the MySmile App, Smile websites and communicating electronically with us, you consent to the processing and transfer of your personal information as set out in this Privacy Policy.

 

3. Notification of changes to the Privacy Policy:

 We are continually improving our methods of communication and adding new functionality and features to the MySmile App, the Smile websites and to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data protection practices will change from time to time. If and when our data protection practices change, we will update this Privacy Policy to describe our new practices. We encourage you to check this page regularly.

 

4. Collecting your personal information:

We are committed to informed and limited collection of essential personal information.

We can get your personal information when you:

• Use the MySmile App;
• Buy a product or service from us (including buying products online, over the phone and in a retail store or other retail outlet) in compliance with local telecom regulations);
• Register for a specific product or service (such as registering your name and address details in compliance with local telecom regulations);
• Subscribe to newsletters, alerts or other services from us;
• Ask us for more information about a product or service, or contact us with a question or complaint.
• Take part in a competition, prize draw or survey;
• Use our network and other Smile products or services.
• Visit or browse our Website or other Smile Group websites.
• With your permission or consent and/or as permitted by law, we may also collect information about you from other organisations or third parties, if this is appropriate and allowed by law. These include fraud-prevention agencies, business directories, and credit reference agencies.

 

5. Understanding what you want (the use of cookies):

We might also use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your movements on our Website). These collect information that makes the website remember you and tells us how you use our Website, web-related products and services.

This, in turn, helps us make our Website relevant to your interests and needs. They also help us find information once you have logged in or help us link your browsing information to you and your personal information, for example, when you choose to register for a service.  We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit our Website again.

Cookies by themselves cannot be used to discover your identity. Cookies do not damage your computer or phone. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. If you choose not to accept cookies from our Website this may limit its functionalities or performance.

 

6. Anonymous data collected through this Website:

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Website. For example, our web server automatically logs which pages of our Website our visitors view, their IP addresses and which web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our Website.

Our Website contains hyperlinks to other pages on our Website. We may use technology to track how often these links are used and which pages on our Website our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

Likewise, if you reached our Website by clicking on a link or advertisement on another website, we also log that information. This assists us to maximize our Internet exposure as well as understand the interests of our users. All of this information is collected and used only in the aggregate: it is entered into our database, where we can use it to generate overall reports on our visitors, but not reports about individual visitors.

We also use your IP address to help diagnose problems with our server and to administer our Website. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups to determine which domain you are coming from to more accurately gauge our users’ demographics.

 

7. The personal information we collect:

The information we may collect about you depends on the Smile products and services you use and subscribe to. It includes (but isn’t limited to) the following:

• Your name, date of birth, home language, address, account information and email address;
• Your preferences for particular products, services or lifestyle activities when you tell us what they are – or when we assume what they are, depending on how you use our products and services;
• Your contact with us – such as a note or recording of a call you make to one of our contact centres, an email or letter you send to us or other records of any contact you have with us;
• Your account information – such as phone number, handset type, handset model, whether you are a prepaid or post-paid customer, dates of payment owed and received, Top-Up information, the subscription services you use or any other information related to your account.

We’ll also get information on how you use our products and services, such as:

• The phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from);
• The date, time and length of the calls and messages you send or receive through our network, and your approximate location at the time these communications take place;
• The level of service you receive – for example, network faults and other network events which may affect our network services;
• Your website browsing information (which includes information about the websites you visit), and about how you use our Website or other Smile Group websites on your mobile or a PC;
• The date, time and length of your internet browsing, and your approximate location at the time of browsing;
• Your location and contact list on your mobile phone when using the MySmile App.

 

8. Use and analysis of your personal information:

We may use and analyse your information to:

• Process the goods and services you’ve bought from us, and keep you updated with your order progress;
• Keep you informed generally about new products and services (unless you choose not to receive our marketing messages);
• 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;
• Contact you with offers or promotions based on how you use our products and services. These include your calling and messaging activities, location information and browsing information (unless you choose not to receive these messages);
• Bill you for using our products or services, or to take the appropriate amount of credit from you;
• To administer this Website and help us improve our services;
• Respond to any questions or concerns you may have about using our network, products or services;
• Let you know about other companies’ products and services we think may interest you (including offers and discounts we’ve specially negotiated for our customers);
• Protect our network and manage the volume of calls, texts and other use of our network. For example, we identify peak periods of use so we can try and ensure the network can handle the volume at 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 personalising the products and services we offer you;
• Carry out research and statistical analysis including to monitor how customers use our network, products and services on an anonymous or personal basis;
• Prevent and detect fraud or other crimes, recover debts or trace those who owe us money;
• Provide aggregated reports to third parties (such reports do not contain any information which may identify you as an individual).

The information we use will include your approximate location, based on the nearest mobile cell site. As a result, this will change as you move around with your mobile phone.

We make use of technologies that enable us to identify your telephone number (MSISDN) if you are accessing some of our websites or apps. This “MSISDN Lookup” capability is only used by us and our trusted partners and is intended to make it easier for you to make use of our services.

We’ll store your information for as long as we have to by law. If there’s no legal requirement, we’ll only store it for as long as we need it.

 

9. Sharing your personal information:

As may be permitted or authorised by law we may share information about you with:

• Smile Telecoms Holdings Ltd;
• Partners or agents involved in delivering the products and services you’ve ordered or used;
• Partners or agents that conduct network performance and customer satisfaction surveys and any other surveys related to the products or services provided to you;
• Companies who are engaged to perform services for and on behalf of Smile;
• Where applicable, credit reference, fraud prevention or business scoring agencies, or other credit scoring agencies;
• Debt collection agencies or other debt recovery organisations;
• Law enforcement agencies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law;
• Emergency services (if you make an emergency call), including your approximate location;
• We’ll release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers;
• If we’re reorganised or sold to another organisation, we may transfer any personal information we hold about you to that organisation.

At your option, and only with your consent, we may also share your information with partner organisations we’ve chosen carefully, so they can contact you about their products and services.

We may share, transfer or disclose the information in our databases and server logs to comply with a legal requirement, for the administration of justice, interacting with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this Website, to take precautions against legal liability, or in the event of our flotation on a stock exchange, sale, merger, reorganisation, dissolution, disposal of all or part of our assets or similar event. We will inform you of any such transfer or disclosure if we are required to do so by law.

Where appropriate, before disclosing personal information to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

In the event of a merger/acquisition or company reorganisation, your personal information may be part of the transferred assets and are likely to be disclosed to the new company.

 

10. Transfer of information:

If you are visiting this Website, the various communications might necessarily result in the transfer of certain non-prohibited information across international boundaries.

We may also need to transfer your information to other Smile Group companies or service providers, in which case we will fully comply with applicable data protection legislation. Countries in the European Economic Area (EEA) are considered to have adequate data protection laws. Other countries outside the EEA may not have relevant data-protection laws, however, we will make sure that your information is protected and enter into appropriate agreements to achieve this.

 

11. Keeping your personal information secure:

We are committed to implementing leading data security safeguards.

We have specialised security teams who constantly review and improve our measures to protect your personal information from unauthorised access, accidental loss, disclosure or destruction.

If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we will ensure that your information is protected and that they only process your information in the way we have authorised them to and as may be permitted by the law. These organisations will not be entitled to use your personal information for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we have set.

Communications over the internet (such as emails) are not secure unless they have been encrypted. Your communications may go through a number of countries before being delivered – as this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that’s beyond our control.

We’ll never ask for your secure personal or account information by unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.

You may choose to disclose your information in certain ways such as social plug-ins (including those offered by Google, Facebook, Twitter and Pinterest) or using third-party services that allow you to post reviews or other information publicly, and a third party could use that information.

Social plug-ins and social applications are operated by the social network themselves and are subject to their own terms of use and privacy and cookies policies. You should make sure you’re familiar with these.

 

12. How to unsubscribe or opt-out:

If you no longer want to receive marketing messages from us, please contact our customer services team or utilize any of the opt out options we have made available to you and you’ll be ‘opted out’. (You can get in touch with customer services through the Contact Us page on our website or MySmile App).

If you choose to unsubscribe or opt out, we will hold your contact details on file marked so that we do not contact you again. This is so that we do not contact you if your details are subsequently provided to us by a third party.

 

13. Access and corrections to personal information:

Under the law, you have the right to access, correct, amend, and delete your personal information or to object to the processing of your personal information.

Upon receipt of your written request and enough information to permit us to identify your personal information, we will disclose to you the personal information we hold about you, for which we may make a charge as allowed by applicable law.

We will also correct, amend or delete any personal information that you tell us is inaccurate and notify any third party recipients of the necessary changes. You may update any information you have given to us by contacting us at our registered address.

Requests to delete personal information are subject to any applicable legal and ethical reporting or document retention obligations imposed on us.

 

14. Unauthorised third party access to your information:

Despite the security measures we have in place to protect your personal information (firewalls, password access and encryption methods) you acknowledge that it may be accessed by unauthorised third party, e.g. as a result of an illegal activity.

 

15. Links to other websites:

Our Website may contain hyperlinks to other websites, such as 3rd party payment platforms or websites for processing of payment of our services or products, which are not operated by us. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any personal information about yourself and others.

 

16. Governing Law:

The laws of the Federal Republic of Nigeria will govern any dispute or claim arising out of or relating to your use of this Website.

 

17.Feedback:

We welcome comments about this Privacy Statement. If you have any questions about this Privacy Policy or any part of our service, you may contact us by sending an e-mail to (gcsupport@smilecoms.com) or by writing to us at the address set out in paragraph 1 of this Privacy Statement. We will store any correspondence from you at our offices.