LEGAL & COMPLIANCE

Privacy Policy

Effective Date: August 5, 2026
SECTION 01

1. Introduction

SmartSurf Communication is committed to protecting the privacy and security of personal information collected from customers and users of our internet and telecommunications services.

SECTION 02

2. Scope

This Policy applies to our website, hotspot services, customer portal, mobile applications, support channels, and related services.

SECTION 03

3. Information We Collect

We collect various types of information to provide and improve our services, including:

  • Personal information (name, address, email address, phone number, and identification documents where legally required).
  • Payment and subscription information (transaction history, payment method details, and plan choices).
  • Technical information (IP address, MAC address, device details, connection logs, signal metrics, and usage statistics).
  • Customer support records, communication logs, and survey feedback.
SECTION 04

4. How We Collect Information

Information is collected during customer registration, plan purchases, hotspot access logins, website visits, support interactions, customer surveys, and automatically through automated network and web technologies.

SECTION 05

5. How We Use Information

We use personal information to fulfill our service commitments, including:

  • Providing, activating, and maintaining internet and telecommunications services.
  • Managing customer accounts, authenticating users, and processing billing transactions.
  • Monitoring, maintaining, and improving network quality, bandwidth distribution, and performance.
  • Providing responsive customer support and technical assistance.
  • Detecting, preventing, and mitigating fraud, unauthorized usage, or security breaches.
  • Complying with applicable legal obligations and regulatory standards in Nigeria.
  • Communicating essential service updates, maintenance notifications, and promotional offers.
SECTION 06

6. Legal Basis for Processing

Processing of personal data is carried out to perform customer contracts, comply with legal and regulatory obligations under Nigerian law, protect legitimate business interests, or with user consent where required.

SECTION 07

7. Cookies and Tracking

Our website and captive portals may use cookies, local storage, and tracking technologies to improve functionality, enhance security, analyze portal usage, and optimize user experience.

SECTION 08

8. Sharing Information

We do not sell personal information. Information may be shared strictly under necessary conditions with payment processors, trusted service providers, infrastructure partners, regulators, or law enforcement agencies when legally required.

SECTION 09

9. Data Security

We implement administrative, technical, and physical safeguards including secure servers, strict access controls, encryption protocols where appropriate, firewalls, network monitoring, and employee confidentiality obligations.

SECTION 10

10. Data Retention

Information is retained only for as long as necessary to deliver services, comply with legal and tax requirements, resolve disputes, and maintain business records before secure deletion or anonymization.

SECTION 11

11. Your Rights

Subject to applicable law, customers have the right to request access to, correction of, deletion of, restriction of, or objection to the processing of their personal information, as well as withdrawal of consent where applicable.

SECTION 12

12. Children's Privacy

Our services are not intended for children under 18 years of age without express parental or legal guardian consent.

SECTION 13

13. International Transfers

Where personal data is transferred or processed outside Nigeria, appropriate legal, technical, and organizational safeguards will be implemented to ensure data security.

SECTION 14

14. Third-Party Websites

SmartSurf Communication is not responsible for the privacy practices or content of third-party websites or services linked to or from our website or captive portals.

SECTION 15

15. Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in our operational practices or legal obligations. Continued use of our services after updates signifies acceptance of the revised Policy.

SECTION 16

16. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact SmartSurf Communication through our official support channels:

SmartSurf Communication Support

Email: smartsurfcommunication@gmail.com / support@smartsurf.com.ng Website: www.smartsurf.com.ng Phone: +234 8027274997 / 0802 727 4997
SECTION 17

17. Consent

By registering for, accessing, or using our services, you acknowledge and consent to the collection, use, storage, and protection of your information as described in this Privacy Policy.