Privacy Policy

1. Introduction

Choice2mobile Technology Limited, trading as Wifiber, is a telecommunications infrastructure provider in Nigeria regulated by the Nigerian Communications Commission (NCC) and operating in compliance with the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR).

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our internet services, subscriber portal website, and mobile application (collectively, the "Services"). By using our Services, you consent to the practices described in this Policy. If you do not agree, please discontinue use of the Services immediately.

2. Who This Policy Applies To

This Policy applies to all subscribers of Wifiber internet services who access the Wifiber subscriber portal or mobile application. Our Services are intended exclusively for individuals aged 18 years and above who have an active service contract with Wifiber.

3. Information We Collect

We collect the following categories of personal information in connection with your use of our Services:

We collect only the information necessary to provide and improve our Services. We do not collect health information or financial account numbers beyond what is needed for payment processing. If you enable biometric login, your biometric data is processed solely by your device's OS and is never transmitted to or stored by Wifiber Broadband.

4. How Your Account Is Created

Wifiber does not offer self-registration through the application. Subscriber accounts are created exclusively by authorised Wifiber administrators following the establishment of your service contract. Your initial profile information — including name, contact details, and RADIUS username — is pre-populated by our team from your contract data.

When an account is created for you, you will receive your login credentials via an approved communication channel. You can update your personal information within the application after your first login, subject to our profile update request process.

5. How We Use Your Information

We use the information we collect for the following purposes:

• Service delivery: To activate, manage, monitor, and support your internet subscription.
• Account management: To authenticate your identity, manage your subscriber account, and process profile update requests.
• Billing & payments: To process subscription payments, generate invoices and receipts, and manage billing disputes.
• Customer support: To receive, track, and resolve support tickets and complaints.
• Communications: To send service notifications, payment confirmations, security alerts, and important account updates via push notification, email, or SMS.
• Service improvement: To analyse usage patterns, diagnose technical issues, and improve the performance and features of our application.
• Legal & regulatory compliance: To comply with applicable Nigerian laws, regulatory requirements from the NCC, and respond to lawful requests from public authorities.
• Security: To detect, prevent, and address fraud, abuse, and other illegal activity.

We do not use your personal information for targeted advertising or sell it to third parties for marketing purposes.

6. Third-Party Services & Payment Processors

To operate our Services, we engage certain trusted third-party service providers. These include:

• Payment processors (e.g., Paystack, Flutterwave, or other NCC-approved gateways): Used to securely process in-app subscription payments. These processors receive your payment details directly through encrypted channels and are subject to their own privacy policies and PCI-DSS compliance obligations. Wifiber does not store full card numbers on its servers.
• Cloud infrastructure providers: We may host application data and services on third-party cloud platforms. All providers are bound by data processing agreements requiring appropriate security measures.
• Analytics & crash reporting tools: We may use tools to collect anonymised crash reports and usage analytics to improve application stability and performance. These tools do not identify you personally.

7. Push Notifications

The Wifiber application may request permission to send you push notifications on your mobile device. We use push notifications for:

• Payment confirmations and billing reminders.
• Subscription expiry and renewal alerts.
• Support ticket status updates.
• Important service announcements and outage notices.
• Promotional communications related to plan upgrades or new features (where you have consented).

You may enable or disable push notifications at any time through your device's notification settings or within the application settings. Disabling notifications will not affect your ability to use core application features, but you may miss important service alerts.

8. App Permissions

The Wifiber application may request the following device permissions to deliver its core features:

We request only the permissions necessary for the application to function. We do not access your camera, microphone, contacts, location, or photo library beyond what is described above.

9. Cookies & Local Storage

The Wifiber web portal may use browser cookies and local storage mechanisms for the following purposes:

• Authentication tokens: To maintain your login session securely without requiring you to re-enter credentials on every page visit.
• Preferences: To remember your theme settings (light/dark mode) and other UI preferences.
• Security: To store a device identifier used to enhance login security.

We do not use third-party advertising cookies or tracking pixels. Session tokens are stored using secure, industry-standard mechanisms and are cleared when you log out or when the session expires due to inactivity.

10. Data Sharing & Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:

• Service providers: With trusted vendors who assist us in operating our business (e.g., payment processors, cloud hosting, analytics), subject to strict data processing agreements and confidentiality obligations.
• Regulatory authorities: With the NCC and other government bodies as required by applicable Nigerian law or valid legal process.
• Legal proceedings: Where disclosure is necessary to protect the rights, property, or safety of Wifiber, our subscribers, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity, subject to equivalent privacy protections.

In all cases, we limit sharing to what is strictly necessary for the stated purpose.

11. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Services. Specific retention periods are as follows:

• Active account data: Retained throughout the duration of your subscription and for a reasonable period thereafter to support dispute resolution and regulatory compliance.
• Billing and transaction records: Retained for a minimum of 6 years as required by Nigerian financial and tax regulations.
• Support ticket and complaint records: Retained for a minimum of 2 years after resolution.
• Technical logs: Retained for up to 12 months for security and diagnostic purposes.

When data is no longer required, we will securely delete or anonymise it in accordance with industry best practices.

12. Your Rights

Under the Nigeria Data Protection Act 2023 (NDPA) and related regulations, you have the following rights regarding your personal data:

• Right to access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data, subject to legal, regulatory, and contractual retention obligations.
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
• Right to object: You may object to certain types of data processing, including direct marketing.
• Right to data portability: Where technically feasible, you may request your data in a structured, machine-readable format.

To exercise any of these rights, please contact our Data Protection Officer at privacy@wifiber.ng. We will respond within 30 days of receiving your request. Some requests may require identity verification before we can process them.

13. Account & Data Deletion

Upon receiving a verified deletion request, we will:

• Deactivate your account access within 7 working days.
• Delete or anonymise your personal profile data within 30 days, except where retention is required by law (see Section 11).
• Send you a confirmation email once deletion is complete.

Please note that some data — such as transaction records and billing history — must be retained for the periods specified in Section 11 to comply with Nigerian financial regulations. Deletion of your account does not entitle you to a refund of any unused subscription.

If you are an Apple App Store or Google Play user, you may also initiate a data deletion request through the respective store's account management features, and we will honour such requests in accordance with this Policy.

14. Children's Privacy

Our Services are strictly intended for adults aged 18 years and above. We do not knowingly collect personal information from children under the age of 13. Since all accounts are created exclusively by authorised Wifiber administrators for verified adult subscribers, no child can gain access to the Services through normal channels.

If we become aware that we have inadvertently collected personal information from a child under 13, we will take immediate steps to delete that information and close the associated account. If you believe a child under 13 has accessed our Services, please contact us at privacy@wifiber.ng.

15. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/HTTPS protocols.
• Secure hashing of passwords — we never store plaintext passwords.
• JWT-based authentication tokens with expiry and automatic refresh mechanisms.
• Inactivity-based session timeout to protect unattended devices.
• Access controls restricting employee access to personal data on a need-to-know basis.
• Regular security reviews of our systems and processes.

While we take all reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant regulatory authority as required by the NDPA.

16. Cross-Border Data Transfers

Your personal data is primarily processed and stored within Nigeria. However, some of our third-party service providers (such as cloud infrastructure or analytics providers) may process data outside Nigeria. Where cross-border transfers occur, we ensure that:

• The recipient country provides an adequate level of data protection, or
• Appropriate safeguards are in place (such as standard contractual clauses or data processing agreements), consistent with the requirements of the NDPA.

17. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will notify you via in-app notification, email, or SMS at least 14 days before the changes take effect.

The current version of this Policy is always available at https://app.wifiber.ng/privacy.html and within the application under Settings > Privacy Policy. Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Policy.

18. Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact our Data Protection Officer:

• Email: privacy@wifiber.ng
• Support email: support@wifiber.ng
• In-app: Settings > Support > Create Ticket (subject: "Privacy Request")
• Lagos office: 33, Akinola Adegunwa Street, Omole Phase 1, Lagos
• Abuja office: 2 Sirasso Crescent, Zone 7, Wuse 900287, Federal Capital Territory
• Lagos phone: 0201 888 3939
• Abuja phone: 0201 888 3931
• WhatsApp: 0916 835 2183
• Regulator: Nigeria Data Protection Commission (NDPC) — ndpc.gov.ng
• NCC: Nigerian Communications Commission — www.ncc.gov.ng

We aim to respond to all privacy-related enquiries within 30 days of receipt.