1. Introduction

NGCOM Networks Limited ("NGCOM", "we", "us", or "our") values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the NGCOM Customer mobile application (the "App") and related services.

Please read this Privacy Policy carefully. By downloading, accessing, or using the NGCOM Customer App, you agree to the collection and use of information in accordance with this policy and applicable data protection regulations (including the Nigeria Data Protection Act - NDPA and GDPR principles where applicable).

2. Information We Collect

We collect information to provide high-speed fiber internet services, account management, identity verification (KYC), billing, and customer support.

A. Information You Provide Directly

• Account & Profile Data: First name, last name, phone number, email address, physical residential address, city, state, zip code, and company name.
• Telecommunication Regulatory Data (NIN): National Identification Number (NIN) collected to comply with Nigerian Communications Commission (NCC) regulations.
• Identity Documents (KYC): Front and back images of government-issued identification documents (e.g., National ID card, International Passport, Voter's Card, Driver's License) uploaded for identity verification and account setup.
• Customer Support & Ticket Communications: Message text, notes, attachments, relocation requests, and feedback submitted through our support desk.

B. Payment & Financial Data

• Payments are processed securely via PCI-DSS compliant third-party payment gateways (Paystack).
• We collect order numbers, payment references, order amounts, plan details, and transaction timestamps.
• Note: We do NOT store full credit card numbers, CVVs, or bank account PINs on our servers. All sensitive payment inputs are handled directly by Paystack.

C. Location Data & Service Metadata

• Location Metadata: New address details, GPS coordinates (latitude and longitude), and estate/LGA details provided during Service Relocation Requests to dispatch technicians and assess fiber infrastructure availability.

D. Local Biometric Data

• Fingerprint / Face ID: If enabled, the App utilizes your device's native biometric hardware (Android BiometricPrompt / iOS LocalAuthentication) for secure sign-in.
• Crucial Note: Biometric data remains strictly stored in your device's secure enclave and is never transmitted to or stored on NGCOM servers.

3. How We Use Your Information

We use the collected information for legitimate business purposes, including:

• Service Provision & Subscription Management: Activating fiber internet packages, managing billing cycles, and enabling subscription renewals.
• Identity Verification & Regulatory Compliance: Verifying customer identities and adhering to NCC guidelines.
• Customer Support: Resolving technical complaints, processing relocation requests, and replying to support tickets.
• Account Security: Authenticating logins, preventing unauthorized access, and securing account recovery.
• Service Communications: Sending transaction receipts, payment notifications, service status alerts, and updates.

4. How We Share Your Information

We do not sell, rent, or trade your personal data to third parties. We share data only in the following necessary contexts:

• Payment Processors: Transaction details are shared with Paystack to complete payments and verify transaction status.
• Field Installation Technicians: Address and contact details are provided to authorized NGCOM field engineers for fiber maintenance and relocation installations.
• Legal & Regulatory Authorities: Data may be disclosed if required by applicable laws, court orders, or official requests from law enforcement or regulatory authorities (e.g., NCC).

5. Data Security & Retention

• Data Security: We implement industry-standard encryption protocols (HTTPS / TLS 1.3) to encrypt all data transmitted between the App and our backend servers.
• Data Retention: Personal data, profile details, and transaction histories are retained for as long as your account remains active or as required by financial, tax, and telecommunication regulations. Uploaded ID documents are securely stored in access-restricted server environments.

6. Your Data Rights & Choices

You have the following rights regarding your personal data:

• Access & Update: You can review and update your phone number, address, city, and state directly inside the Profile section of the App.
• Account Deletion / Data Removal: You can request account closure and deletion of non-regulatory personal data by contacting privacy@ngcomnetworks.com.
• Biometric Auth Toggle: You can enable or disable Biometric Authentication at any time in the App's Security Preferences.

7. Children's Privacy

The NGCOM Customer App is intended for adult subscribers aged 18 and older. We do not knowingly collect or solicit personal data from children under 13 years of age.

8. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Any updates will be posted within the App, and the "Effective Date" at the top will be updated accordingly.