MTNN Nigeria Communications PLC (“MTNN”), a public limited liability company, incorporated in
the Federal Republic of Nigeria with registration number 395010 and its principal office at MTNN
Plaza, Falomo Roundabout, Awolowo Road, Ikoyi, Lagos, respects the privacy of our Customers’
Personal Information which should be protected through the use and interaction with
www.mtn.ng and all associated websites, mobile MTNN Fleet Applications, products and services.
We have prepared this MTNN Insider Customer Privacy Notice (this “Privacy Notice or “Notice”) to
notify You of the type of Personal Information we collect from You, Our Customers and/or Users;
how We will treat that Personal Information; and the circumstances under which We will share it
with third parties.

Internal Customers who are staff of the organisation may only use MTNN Fleet MTNN Fleet App
MTNN Fleet Applications, and services with authorisation from the organisation.

This Notice MTNN Fleet Applies to:
• all Internal Customers and Users.

Through the MTNN Fleet MTNN Fleet App, which You are subscribing to, you may be requested to
provide Your Personal vehicle Information.

Existing personal information you already provided to MTNN as an employee.

Your information would include but not be limited to name and registered MTN region and other
details etc.

Cookies
A cookie is generally a tiny data file that resides on Your mobile phone. There are different types
of cookies. Here are two examples:

A “persistent” cookie – this cookie is set once You have logged on to a website. The next time You
visit the website, the persistent cookie will allow the website to recognise You as an existing user or
registered user, so You will not need to log in before using the services.

You can remove or block cookies using the settings in Your browser, but in some cases doing so
may impact Your ability to use the MTNN Fleet Application.

By accepting to this privacy notice you consented to the use and processing of the personal
information you provided via this MTNN Fleet Application and existing information provided to
MTNN or its affiliates as an MTNN employee.

7. The use of Your Personal Information

To provide You with the best mobile MTNN Fleet Applications travel services, MTNN will use Your Personal Information to:

• Process your trip request that you make using MTNN Fleet MTNN Fleet App MTNN Fleet App, and keep You updated with Your trip progress.
• Process trip, and distance covered and credit the MTNN Fleet Appropriate amount for the trip based on your region
• Provide the relevant travel services to You
• Understand how You use the MTNN Fleet MTNN Fleet App MTNN Fleet Application, and services. That way, we can develop more interesting and relevant products and services, as well as personalise the products and services We offer You
• Carry out research and statistical analysis to monitor how Customers and/or users’ use Our
• MTNN Fleet MTNN Fleet App, and services on an anonymous or personal basis
• Prevent and detect fraud, information security and privacy incidents and other crimes, recover debts or trace those who owe Us money.
• Contact You in the event of a query and respond to any questions or concerns You may have about using MTNN Fleet MTNN Fleet App MTNN Fleet App and services
• Where Your Personal Information is required other than in respect of the aforementioned, MTNN shall notify You of such other purpose for which Your Personal Information is required to enable You to provide Your consent.

• Maintaining the security of Your Personal Information is important to MTNN. Reasonable security safeguards have been implemented to protect Your Personal Information. MTNN uses various methods to protect Your information such as:
• Encryption methods when transmitting personal information, such as Your vehicle details
• Access to Your Personal Information on mobile MTNN Fleet Applications will be encrypted and/or password protected.
• To protect any data, MTNN regularly audits its systems for possible vulnerabilities and attacks.
• MTNN maintains an Information Security Programme internally to ensure that Your Personal Information is protected against unauthorised access, accidental loss or destruction.

MTNN will not share Your Personal Information to third parties except where necessary to enhance
the provision of our services to You and it will be made with your consent;
MTNN will never publicly disclose any personal and sensitive user data related to financial or
payment activities or any government identification numbers.
There will be circumstances where We are obliged to disclose Your information by law and are
prohibited from informing You when we have received a request for Your Personal Information in
relation to any suspected or alleged criminal activity.
In addition, companies employed by MTNN to perform certain functions (“Third Parties”) may be
assessed to ensure that they handle Your information securely. Some of MTNN Third Parties perform
the following functions for MTNN:

• Receiving payments, fulfilling orders, and email, removing repetitive information from customer
  lists, analysing data, providing market assistance, providing search results and links (including
  paid listings and links), processing credit card payment, and providing customer service

These Third Parties have access to Personal Information needed to perform their functions and for
purposes clearly defined by MTNN.
MTNN will never allow unauthorized publishing or disclosure of Your contact details to the public.

Erasing Your information

You have the right to request that MTNN erase your Personal Vehicle Data if it is no longer valid or
necessary for the purposes for which it was collected or if it is incomplete or inaccurate.

Receiving your information

You have the right to receive your Personal Data in a commonly used and machine-readable
format and the right to transmit these data to another Data Controller when the processing is
based on (explicit) consent or when the processing is necessary for the performance of a
contract.

10.1 Accessing and Changing Your Vehicle Information

You can review the information You provide to Us and make any desired changes to the
information You have provided. Please be aware that even after Your request for a change is
processed, MTNN may, for a time, retain residual information about You in its backup and/or
archival copies of its database.

10.2 Direct Marketing

There will be no form of marketing
We do comply with MTNN Fleet Applicable provisions of the laws and relevant Consumer
Protection regulations on direct marketing.

10.3 Deletion or destruction of Your Information and Period of Retention

10.3.1 You may request that we delete and destroy any of Your Personal Vehicle Information
provided that Your relationship with MTNN has been MTNN Fleet Appropriately terminated.

10.3.2 MTNN will, however, retain and use Your Personal Vehicle Information in accordance with
MTNN Fleet Applicable laws for retention of data, for as long as is necessary to provide You with
Our services and comply with legal and business obligations, resolution of disputes and
enforcement of this Notice among others.

10.4 Transfer and storage of Personal Information across borders

• You understand that MTNN may be required to host, process, transfer and store Your Personal
  Information in other countries for business purposes which could include giving effect to a thirdparty contract for Your benefit or Your protection.
• MTNN shall ensure that the countries have adequate data protection laws, corporate security
  policies, procedures and standards to adequately protect Your Personal Information as
  prescribed by NDPR.
• Your Personal Information shall be stored in Oracle Advanced Security Transparent Data
  Encryption format using Generally Accepted International Security Standards (ISO).
• Your Personal Information shall be subject to the Nigerian Data Protection Regulation 2019 (as
  may be amended from time to time) and any other MTNN Fleet Applicable Data Protection
  Regulation.

10.5 Right to withdraw consent
You have a right to withdraw Your consent at any time without affecting the lawfulness of Your
information received and processed by MTNN in line any legal obligation or prior to Your
withdrawal of consent.

10. 6 Reporting incidents
In the event of a privacy breach, MTNN shall report such breach to the relevant authority and if
necessary, affected individuals of personal data breach (where the personal data breach will
likely result in high risks to the freedoms and rights of the data subject) within reasonable time of
being aware of the breach.
MTNN shall take steps to investigate and recover personal data. MTNN will also ensure that controls
are enhanced to prevent a re-occurrence of the breach.
You have a right to lodge a complaint before an MTNN Fleet Appropriate authority for any breach
of Your rights.

Kindly notify Us:

• If You believe Your MTNN platform via website and/or mobile MTNN Fleet Application or
  subscription account to MTNN products and services has been compromised.
• If You have been contacted by someone via email or SMS about Your mobile MTNN Fleet
  Applications, products and services account asking for a password, or other personal
  information.
• If You believe Your Personal Information has been used for fraudulent activity.

1. If You are a member of the security community and need to report a technical vulnerability.

• If You have any other enquiry relating to information privacy and security.

As a Customer and/or user, there are certain obligations expected from You. Some of these
obligations are imposed by MTNN Fleet Applicable law and regulations, and others have become
commonplace for MTNN:

• You must always abide by the terms and conditions of this Notice and any agreement relating
  to MTNN products and services that You have subscribed to. This includes respecting all
  intellectual property rights that may belong to Third Parties (such as trademarks or
  photographs).
• You must not download or otherwise disseminate any information that may be deemed to be
  injurious, violent, offensive, racist or xenophobic, discriminates against people on the basis of
  gender and sexual orientation threatens the rights and safety of others, or which may otherwise
  violate the purpose and spirit of MTNN and its community of users on MTNN websites and/or
  mobile MTNN Fleet Applications.
• You must not provide MTNN with information that You believe might be false or misleading.
• You must keep Your username and password confidential and not share it with others.
• Promptly notify MTNN at the Contact Details indicated below, where You wish to exercise any
  of Your rights with respect to Your Personal Information.

MTNN may, at any time, change its Privacy policy and this Privacy Notice by posting the amended
version on www.mtn.ng. Unless otherwise stated, the current version will MTNN Fleet Apply each time You access this website.

Attention: Data Processing Officer
Address: MTNN Nigeria Communications PLC
Email address: DPONigeria@MTNN.com

Last updated December 2022