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PRIVACY NOTTICE

Introduction
Your privacy is important to us. We endeavour to ensure that our use of your personal information is lawful and relevant to our business activities with the aim of improving our services and your experience.
This Privacy Notice is designed to help you understand our privacy practices and procedures regarding what information and personal data we collect when you use our website (which includes our online platform, mobile application and other platforms), why we collect it, and what we do with it, as well as your rights regarding the processing of your personal data by us.
Who we are
Telairvision Limited (“Telairvision”, “our”, “we” or “us”) is licensed in Nigeria to provide IPTV service that offers television shows and video streaming content in Nigeria. For questions specifically about this Privacy Notice, or our use of your personal information, or our Cookies Policy, please contact our Data Protection Officer/Privacy Officer by email at [email protected]
The data controller of your personal information is Telairvision. Please note that if you contact us to assist you, we may need to authenticate your identity before fulfilling your request.
Application of this Privacy Notice
This Privacy Notice applies to you as a person who subscribes to any of our services, registers on any of our platforms; or accesses any of our platforms, regardless of the device which you use to access it. This Privacy Notice does not apply other parties’ sites which link to or advertise on our platforms.
What do we mean by personal information?
Personal information refers to information about an identifiable human being such as your name, gender, age, date of birth, contact address, email, phone number, identification card number, your picture, your bank details. Other information that qualifies as personal information include:
· Device information: Internet Protocol address, unique device identifier, the nature and type of device which you use to access our site, the geographical location of your device.
· Log information: Information relating to how, when and for how long your access and use our site; pages you accessed and viewed and the time spent and what you did on the pages you accessed; your interests in terms of our services and products, including but not limited to shows, programs and movies you like; and how you interact with other users of the sites.
· Location information: We may use various technologies to ascertain your actual location, such as geographical data from your device.
The Personal Information We Collect
We receive and store information about you such as:
· Information you provide to us: We collect information you provide to us when you use our service which includes:
o your name, email address, billing address, payment method(s), telephone number, your date of birth, username and password, authentication method(s), and other identifiers you might use, gender, profile picture, physical location and other information which we may request from you from time to time. We collect this information in a number of ways, including when you enter it while using our service, interact with our customer service, or participate in surveys or marketing promotions;
o information when you choose to provide ratings, taste preferences, account settings or otherwise provide information to us through our service or elsewhere.
· Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your network, network devices, and your computer or devices you may use to access our service. We collect this information using various technological means. This information includes:
o your activity on our site, such as title selections, shows you have watched, and search queries;
o your interactions with our emails and texts, and with our messages through any messaging channels;
o details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
o device IDs or other unique identifiers, including for your network devices;
o advertising identifiers such as those on mobile devices, tablets, and streaming media devices that include such identifiers (see our "Cookies Policy" for more information);
o device and software characteristics (such as type and configuration), connection information including type (wifi, cellular), statistics on page views, IP address (which may tell us your general location), browser and standard web server log information;
o information collected via the use of cookies including ad data (See our "Cookies Policy" for more details.).
· Information from partners: We collect information from other companies with whom you have a relationship (“Partners”). These Partners might include (depending on what services you use): your TV or internet service provider, or other streaming media device providers who make our service available on their device; mobile phone carriers or other companies who provide services
to you and collect payment for the Telairvision service for remittance to us or provide pre-paid promotions for the Telairvision service; and voice assistant platform providers who enable interaction with our service through voice commands. The information Partners provide us varies depending on the nature of the Partner services, and may include:
o search queries and commands applicable to us that you make through Partner devices or voice assistant platforms;
o service activation information such as your email address or other contact information;
o IP addresses, device IDs or other unique identifiers, as well as associated pre-paid promotion, billing and user interface information, that support user authentication, the Telairvision service registration experience, Partner payment processing, and the presentation of our content to you through portions of the Partner user interface.
· Information from other sources: We also obtain information from other sources. We protect this information according to the practices described in this Privacy Notice, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include:
o service providers that help us determine a location based on your IP address in order to customize our service and for other uses consistent with this Privacy Notice;
o security service providers who provide us with information to secure our systems, prevent fraud and help us protect the security of our sites and your account with us;
o payment service providers who provide us with payment or balance information, or updates to that information, based on their relationship with you;
o online and offline data providers, from which we obtain aggregated demographic, interest based and online advertising related data;
o publicly-available sources such as publicly available posts on social media platforms and information available through public databases associating IP addresses with internet service providers (ISPs)
Why and How We Use Your Personal Information
We will only process your personal information when the law allows us to, that is, when we have a legal basis for processing. We use your personal data in the following circumstances:
· “Performance of a contract”: where we need to provide you with our services in line with the contract which we are about to enter into or have entered into with you as a party or to take steps at your request before entering into such a contract;
· “Legal or regulatory obligation”: where we need to comply with a legal or regulatory obligation that we are subject to;
· “Consent”: where you have provided your consent to processing your personal data.
Consent in this context means any freely given, specific, informed and unambiguous indication of your approval to the processing of your personal information. Consent may be made through a written statement, or an affirmative action signifying agreement to the processing of personal information. We will not process your personal information on the basis of consent unless your consent is explicit, precise and given to us for a specific purpose. With limited exceptions (for instance, in relation to some of our electronic marketing), generally we do not rely on consent as the legal basis for processing your personal information. You have the right to withdraw consent to electronic marketing at any time by following the unsubscribe instructions in such marketing materials or by contacting us at [email protected]
Processing personal information in the context of this Privacy Notice means any operation or set of operations which we perform on your personal information. such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, combination, restriction, erasure or destruction.
We use your personal information which we collect to provide, analyse, administer, enhance and personalise our services and marketing efforts, to manage referrals, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use such information to:
· establish and verify your identity;
· create an account for you and to ensure that your account does not duplicate an existing user account on our site;
· provide you with our services and products;
· maintain and update our database;
· fulfil any contractual obligations we may have to you and to fulfil legal obligation we have to government agencies and third parties;
· determine your general geographic location, provide localised content, provide you with customised and personalised viewing recommendations for movies, TV shows and other programmes we think will be of interest to you, determine your ISP to support network troubleshooting for you (we also use aggregated ISP information for operational and business purposes), and help us quickly and efficiently respond to inquiries and requests;
· coordinate with Partners on making our service available to subscribers and providing information to non-subscribers about the availability of our service, based on the specific relationship you have with the Partner;
· secure our systems, prevent fraud and help us protect the security of your account;
· inform you of facts relating to your access to and use of your account and our site;
· inform you about our products and services which we think may interest you (as long as you have consented to this);
· inform you about any changes to our site, products, services, our terms of use, this Privacy Notice, or any other changes that may be relevant to you;
· prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms (such as determining whether and for which Telairvision promotional offers you are eligible and determining whether a particular device is permitted to use the account consistent with our Terms of Use);
· analyze and understand our audience, improve our service (including our user interface experiences and service performance) and optimise content selection, recommendation algorithms and delivery;
· request feedback on our site, products and services, address any issues and liaise with subscribers in that regard;
· improve your user experience and overall quality of our services;
· keep a record of our communication with you and of your communication with us;
· communicate with you concerning our services so that we can send you news about Telairvision, details about new features and content available on our platform, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message or online messaging channels;
· carry out marketing, product research and marketing;
· compile and use statistical information about you and other users and their access to and use of our site, browsing habits, click patterns and preferences, demographics etc. which we may use to develop, provide and improve our platforms, products and services;
· other activities not specifically mentioned which are lawful, reasonable and relevant to our business activities, and the minimum necessary and adequate for us to provide you with our services and products.
We will get your consent before processing your personal information for any other purpose.
Disclosure of Information
We will not disclose, for commercial gain or otherwise, your personal information other than as set out in this Privacy Notice or with your consent. We may disclose or share your personal information to or with any of the following for certain purposes: · Our Affiliates: We share may share personal information any affiliate of Telairvision for: providing you with access to our services; providing customer support; making decisions about service improvements; content development; providing services to us; and for other purposes described in the Why and How We Use Your Personal Information section of this Privacy Notice. · Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customise, personalise and optimise our service, to process card transactions or other payment methods, to provide customer service, to analyse and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal information. We do not authorise them to use or disclose your personal information except in connection with providing their services. · Partners: As described above, you may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing our service to you and providing information about the availability of our service. For example, depending on what Partner services you use, we may share information:
o in order to facilitate Partner pre-paid promotions or collection of payment for our service;
o with Partners who operate voice assistant platforms that allow you to interact with our service using voice commands;
o so that content and features available on our platform can be suggested to you in the Partner’s user interface. For subscribers, these suggestions are part of our services and may include customised and personalised viewing recommendations.
· Promotional offers: We may offer joint promotions or programmes that, in order for your participation, will require us to share your personal information with third parties. In fulfilling these types of promotions, we may share personal information with the third party concerned. Please note that these third parties are responsible for their own privacy practices.
· Protection of Telairvision and others: Telairvision and its Service Providers may disclose and otherwise use your personal information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Telairvision, its users or the public, as required or permitted by law.
· Business transfers: In connection with any reorganisation, restructuring, merger, acquisition, take over or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Notice.
Whenever in the course of sharing information we transfer your personal information to other countries, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection.
Retention of Your Personal Information
We retain all personal information which we collect from you unless there is a valid technical, legal or business reason for us to delete, destroy or de-identify it (“retained information”). We will keep all retained information as long as your account with us remains active or as long as you access our site.
When your permanently deactivate/delete your account, we will only retain your personal information for as long as necessary to fulfil the purposes such as satisfaction of any legal, regulatory, accounting, reporting requirements, for the establishment or defense of legal claims (“retention period”). After the retention period, we will delete/destroy your personal information in accordance with the applicable laws. To determine the appropriate retention period for your personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, and the applicable legal requirements. If you would like to know more about the retention periods we apply to your personal data, please contact us at [email protected]
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information. It is Telairvision’s policy to respect your rights and Telairvision will act promptly and in accordance with any applicable law, rule or regulation relating to the processing of your personal information.
Details of your rights are set out below:
· right to be informed about how your personal information is processed – you have a right to be informed about how we will use and share your personal information. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language. Please refer to the Why and How We Use Your Personal Information section of this Privacy Notice to see how we will use your personal information;
· right to access personal information – you have a right to obtain confirmation of whether we are processing your personal information, access to your personal information and information regarding how your personal information is being used by us;
· right to have inaccurate personal information rectified – you have a right to have any inaccurate or incomplete personal information rectified. If we have disclosed the relevant personal information to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible;
· right to have personal information erased in certain circumstances – you have a right to request that certain personal information held by us is erased. This is not a blanket right to require all personal data to be deleted. We will consider each request carefully in accordance with the requirements of the applicable data protection law;
· right to restrict processing of personal information in certain circumstances – you have a right to block the processing of your personal information in certain circumstances. This right arises if you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead or if the personal data is no longer required by us, but you require the personal data to be retained to establish, exercise or defend a legal claim;
· right to data portability – in certain circumstances you can request to receive a copy of your personal information in a commonly used electronic format as well as the right to request that the personal information be transferred to another person. This right only applies to personal information that you have provided to us (for example information provided to us when signing up or subscribing to our service). Information about you which has been gathered by monitoring your behavior will also be subject to the right to data portability;
· right to object to processing of personal information in certain circumstances, including where personal information is used for marketing purposes – you have a right to object to processing being carried out by us if (a) we are processing personal data for the performance of a task in the public interest, (b) if we are using personal data for direct marketing purposes, or (c) if information is being processed for scientific or historical research or statistical purposes.
You may exercise any of your rights by contacting our Data Protection Officer a [email protected] you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may refuse to comply with your request in appropriate circumstances prescribed by the applicable data protection law.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive
it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Security
All personal information you provide to us is stored on our secure servers or those of our trusted Partners. We implement appropriate technical, organisational, administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.
Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information transmitted to our servers using the internet; any such transmission is at your own risk. Once we have received your personal information, we will use the procedures and security features described above to prevent unauthorised access of your personal information.
From time to time, we review our information collection, storage, and processing practices including the technical, organisational, administrative, logical, and physical security measures to keep up to date with industry best practice. We create a secure back-up for operational and safety purposes.
Direct Marketing
We will not send you marketing materials if you have requested not to receive them. When you register on our site, you may choose whether to receive marketing materials from us. You may refuse to accept or require us to discontinue sending marketing materials to you. If you request that we stop processing your personal information for marketing purposes, we shall stop processing your personal data for those purposes. You may opt out of receiving marketing materials from us (a) at the time of registering on our site by not ticking the relevant “opt in” box; and (b) at any time by requesting us to desist from sending any direct marketing materials to you.
We would encourage you to make such requests via the forms and links provided for that purpose in the marketing materials we send you or by contacting our Data Protection Officer [email protected]
Other Websites, Platforms and Applications
We may be provided our services through and/or utilise features operated by third party platforms, or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to access our service through platforms such as smart TVs, mobile devices, and a number of other internet connected devices. These websites and platforms have separate and independent privacy policies, privacy notices and terms of use, which we recommend you read carefully. In addition, you may encounter third party applications that interact with our service.
We are not responsible for the privacy practices of a third-party site to which there may be a link on our site or to which you may log in from our site.
Children
You must be at least 13 years of age or older to subscribe to our service. Children below the age of thirteen can only use our service with the involvement, supervision, and approval of a parent or legal guardian.
Changes to this Privacy Notice
We will update this Privacy Notice from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of our service after any such updates take effect will constitute acknowledgement and acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Notice, you may cancel your use of our service.
Complaints
If you have a concern about the way we are processing your personal information, please send an email to our Data Protection Officer at [email protected] stating your name contact address such as your email and phone number, your username, what you think we have done wrong, and all relevant information and evidence in support of the complaint. While we try to respond as promptly as possible, resolution time will vary depending on the nature of the complaint. You will be notified of the outcome of your complaint as well as any action taken.
If you are unhappy with the outcome of your complaint or how the complaint was handled, then you may appeal by writing to our head of compliance at [email protected] outlining your reasons.
If you remain unhappy after the appeal process, you may forward your complaint to the Nigerian Data Protection Bureau at https://app.ndpb.gov.ng/BreachReports/Create
COOKIES POLICY
We and our Service Providers use cookies for various reasons. We want you to be informed about our use of these technology. The Cookies Policy explains the types of technologies we use, what they do, and your choices regarding their use.
About Cookies
A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We use other technologies such as browser storage and plugins. Like cookies, these other technologies may store small amounts of data on your device.
Why we Use Cookies
We use these types of technologies for various reasons, including:
· Authentication: we or Service Providers use cookies to identify you when you visit our website and as you navigate on our website;
· Status: we or Service Providers use cookies to help us determine if you are logged into our site;
· Personalisation: we or Service Providers use cookies to store information about your preferences and to personalise our site and services for you;
· Advertising: we or Service Providers use cookies to help us display advertisements that will be relevant to you;
· Analysis: we or Service Providers use cookies to help us analyse the use and performance of our services and site;
· Accuracy: we or Service Providers use cookies to help us ensure that our records are complete and up to date.
Other purposes for which we use cookies include making it easy to access our services by remembering you when you return; to enforce our terms, prevent fraud; to improve site performance, monitor visitor traffic and actions on our site; and to understand interactions with our emails, marketing, and online ads on third party sites.
The information which we or Service Providers may passively collect from your device may include your identifying information, contact details, device information, site activity information, log information, location information and any other information which you may permit us, from time to time, to collect from your device.
To help you better understand how we use cookies, we have provided the following information:
· Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we and our Service Providers may use these cookies to authenticate and identify our subscribers when they use our websites and applications so we can provide our service to them. They also help us to enforce our Terms of Use, prevent fraud and maintain the security of our service.
· Performance and functionality cookies: These cookies help us to customise and enhance your online experience with us. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided. We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our subscribers’ use of our service so that we can enhance and personalise our website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of our service.
· Advertising cookies: These cookies use information about your use of our site and other websites and apps, your response to ads and emails to deliver ads that are more relevant to you and for analytics and optimisation purposes.
In connection with our use of cookies, some of the websites and apps where we advertise, as well as advertising technology companies that we use to purchase, deliver, optimise, and/or measure our advertisements, may receive limited information from us as part of our campaign targeting, measurement, and optimisation. Common uses of this type of information are to judge the effectiveness of and optimise ad campaigns, by allowing our Advertisers to see when someone who saw an ad later signed up for our service. Another common use is to make sure we do not serve ads trying to get individuals to sign up for our service if they are already subscribed to our service.
We use contractual and technical measures designed to prevent Advertiser from accessing information regarding specific title selections you make, URLs you land on, or shows you have watched on our service. We do not share information about title selections or your shows you have watched on our service.
Managing Cookies
For more information about how you can manage the cookies we use and to exercise choices regarding them, click here.
This Privacy Notice was last updated on November 15, 2022.