Privacy Notice - Milsat Technologies

1. Introduction

Milsat Technologies Limited (“Milsat”, “we”, “us”, or “our”) is a data collection and analysis organisation providing data collection services to its clients.

This Privacy Notice (“Notice”) governs your use of our website, artificial intelligence chatbot, or application (collectively, the “Platform”). We provide this Notice because you have a right to know what information we collect, why we collect it, how it is protected and used, and the circumstances under which it may be disclosed.

2. How We Collect Data

Direct interactions: with us in person, by post, phone, email or otherwise. You may give us your Identity and Contact data.
Automated technologies or interactions: with our website, by using the inquiry form, by signing up on our platform, or by purchasing Milsat Technologies products through our website.
Third parties or publicly available sources: we use publicly available sources to collect data.

3. The Data That We Process

Personal data is any information about an individual that can identify that person directly or indirectly. While using the Platform, we process personal information from you to contact or identify you, and some information may be collected automatically for our website to function properly. We also collect personal data through your use of our services, such as when you create a profile or register to join our community. We collect the following information:

Service users	All visitors
Identity Data: includes forenames, last name, date of birth, gender, marital status, and username or similar identifier. Contact Data: may include invoicing, purchase order, home or work address, email address, telephone numbers, personal or job title, and position. Technical Data: may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this Website. Profile and Usage Data: may include inquiries submitted by you, feedback and survey responses, and how you use our website, products, and services. Aggregated Data: non-personal data obtained from your personal data which does not directly or indirectly identify you, such as usage detailing interactions with our website and product areas.	Profile and Usage Data: may include inquiries submitted by you, feedback and survey responses, and how you use our website, products, and services. Aggregated Data: non-personal data obtained from your personal data which does not directly or indirectly identify you, such as usage detailing interactions with our website and product areas.

Service users

All visitors

Identity Data: includes forenames, last name, date of birth, gender, marital status, and username or similar identifier.
Contact Data: may include invoicing, purchase order, home or work address, email address, telephone numbers, personal or job title, and position.
Technical Data: may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this Website.
Profile and Usage Data: may include inquiries submitted by you, feedback and survey responses, and how you use our website, products, and services.
Aggregated Data: non-personal data obtained from your personal data which does not directly or indirectly identify you, such as usage detailing interactions with our website and product areas.

Profile and Usage Data: may include inquiries submitted by you, feedback and survey responses, and how you use our website, products, and services.
Aggregated Data: non-personal data obtained from your personal data which does not directly or indirectly identify you, such as usage detailing interactions with our website and product areas.

4. Cookies and Tracking Technologies

We use tracking technologies on our website, and information about their usage is specified in our Cookies and tracking technologies notice.

5. Lawful Bases for Processing Data

We are required to process your data under at least one of these lawful bases, as specified under the relevant data protection laws:

Legitimate interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, unless our legitimate interests are outweighed by your interest, in which case we may not rely on this lawful basis.
Consent: You have given explicit consent for us to process your data for a specific purpose.
Contract: If the data processing is necessary for a contract with us or because we have asked you to take specific steps before entering that contract.
Legal obligation: If the processing of your data is necessary where there is a statutory obligation on us.

6. Purpose of Processing Your Data and the Lawful Bases

Purpose of Processing	Lawful Bases
To help us develop, improve, customise, or restructure our community. To inform you whenever there are changes to our terms of use or services. To collect statistical data and analytics for our internal use. To analyse usage and provide, maintain, and improve our application’s content and functionality.	Legitimate interest
To send marketing or promotional messages to you.	Consent
To secure your data and prevent fraud. For identity verification and fulfilling KYC (Know Your Customer) obligations	Legitimate interest, legal obligation
To administer our services through the use of our Platform. To enforce our terms of use and any terms and conditions of any other agreements for our services. To communicate with you and ensure user support. To address your inquiries, process registration, and complete transactions. To contact you for account verification, alerts, and customer support	Contract
To verify your location for eligibility; comply with anti-money laundering (AML) laws To interact with regulatory authorities or other public authorities concerning you.	Legal obligation

7. Your Rights as a Data Subject

You are vested with certain rights as a data subject. They include the right to:

access personal data we hold about you by requesting a copy;
rectify such information where you believe it to be inaccurate or outdated;
restrict the processing of your data in certain circumstances;
object to the processing of your data where we intend to process such data for marketing purposes;
where feasible, receive all personal data you have provided to us—in a structured, commonly used, and machine-readable format—and transmit the information to another data controller;
request the erasure of your data (also known as the right to be forgotten);
withdraw your consent to processing your data;
lodge a complaint with the Nigeria Data Protection Commission (NDPC) where you have reason to believe that we have violated the terms of this Notice. (You may complain or seek redress from us within 30 days from when you first detected the alleged violation.) You can reach the NDPC at info@ndpc.gov.ng.

You may seek to exercise any of the above rights by emailing us at support@milsat.tech or our DPO at dpo@milsat.tech.

9. Who Do We Disclose Data To?

We may share your data with third parties. When using the Platform, we share your data with the following third parties:

Third Parties	Purpose of data sharing
Legal and Regulatory Authority	We may disclose your personal information if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, or audit, protect any person’s safety, or address fraud, security, or technical issues.
Service providers	We may share your personal data with service providers, their affiliates and partner financial institutions to facilitate various tasks such as payment processing, data processing on our behalf, etc. and help us fulfill our obligations to you.
Advertisers and analytics companies	We may share your data with third-party advertisers and analytics companies to provide ads on the platform and to understand user engagement.

10. Retention of Your Data

The personal data we process will be stored for as long as necessary to fulfil the purposes described in this Notice. However, we will also retain data subject to relevant provisions of applicable laws, resolve disputes, prevent fraud and abuse, and enforce our legal agreements and policies. In addition, we delete your data for targeted marketing purposes once you unsubscribe from our marketing communications and request that the data be deleted.

Please note that your data may be retained for a longer period, notwithstanding your request to remove it, where there is a legal requirement to do so.

11. Security of Data

We prioritise your privacy and use advanced measures to protect your data. While no online platform is entirely foolproof, we are dedicated to safeguarding your information against loss, misuse, and unauthorised access. If a significant breach occurs, we will promptly inform you and act swiftly to address it.

12. International Transfer of Data

We transfer personal data outside our country of operation. We ensure any cross-border data transfers adhere to all necessary data protection regulations. This means that before transferring personal data, we either confirm that the recipient country has robust data protection laws or, if not, employ specific contractual terms and other safeguards to protect the data. If the destination country may not meet stringent data protection standards, we will use the relevant data transfer mechanism, seek authorisation from the regulator, or obtain your consent before proceeding, and we will inform you of any risks. Should you wish to learn more about how we ensure data protection during these transfers, details will be provided upon request.

13. Marketing and Communications

We only send marketing communications to you with your consent. You can opt out of our marketing or object to further processing by contacting us via email at dpo@milsat.tech and requesting to discontinue receiving marketing messages.

14. Complaints

If you have any inquiries or complaints, please contact our Data Protection Officer (DPO) at dpo@milsat.tech. Our DPO will examine your concerns and update you on the resolution process.

15. Changes to This Notice

We update our privacy notice occasionally. We will notify our users when we make a change, and visitors will know this by checking the last date of the update on this page whenever they visit.

16. Contact Us

If you have any questions relating to this Notice, your rights under this Notice, or you are not satisfied with how we manage your personal data, kindly contact our Data Protection Officer at dpo@milsat.tech.