MTL - Malawi Telecommunications Limited

PRIVACY POLICY FOR MALAWI TELECOMMUNICATIONS LIMITED (MTL)

Privacy Statement

In order to provide you with the full range of MTL products and products and services, we sometimes need to collect information about you. Your privacy is very important to us hence MTL is committed to respecting, safeguarding and protecting you and your family's personal information collected by us. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information and international best practices on data protection and privacy.

To demonstrate our commitment, MTL has created this Privacy Policy in order to communicate its intent to provide effective processes for the appropriate handling of such private information and to comply with applicable legislation that governs the authentication, protection and disclosure of personal information. This Privacy Policy relates to our use of any personal information you provide to us online, via phone or text, by email, in letters or correspondence of through whatever means.

All access and use of the MTL website, products and services and products is subject to the terms and conditions of this policy.

Disclaimer

Please be aware that Internet communications are inherently insecure unless they have been encrypted. Your communications may be routed through any number of countries and networks before reaching our network and website. MTL therefore assumes no responsibility or liability of any nature whatsoever for the interception or loss of personal information beyond our control.

From time to time MTL website will provide links to other websites. These third party websites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information you submit or is collected by cookies whilst visiting these websites. MTL is not responsible for the content of, or the products and services offered by those sites. The hyper-links are provided solely for your convenience and should not be construed as an express or implied endorsement by MTL of the sites or the products or products and services provided therein. You access those sites and use their products and products and services solely at your own risk.

MTL makes every effort to ensure that any personal information it has about you is protected and not abused. Further MTL makes every effort to ensure that any file available to be downloaded from its website is free of software viruses. However, due to unforeseen circumstances, unlawful and unauthorized access and acts, it cannot guarantee that your personal data shall always be safe and that all materials downloaded from our website are free of any software virus or malicious content. MTL shall therefore not be responsible for any loss or damage howsoever caused by unlawful access to personal data and access to or use of files downloaded from our web site.

Whilst every effort has been made by MTL, and its suppliers of information, to ensure the proper performance of its website, the accuracy of the information/images and the reliability of data / information on its website, MTL and, its affiliated partners, or any of their employees, do not guarantee the availability of products and products and services, content and information offered on its website or the accuracy of the information and/or images on its website.

What type of information is collected, and when is it collected

When you participate in, access or sign up to any of the MTL's products and services, activities or online content, such as newsletters, competitions, live chats, message boards, telephone or text or create an account using the MTL's online registration system we may receive personal information about you.

Such information may include, but is not limited to, your name, address, telephone number, email, date of birth, whether you are a post or prepaid customer and type of products and services you typically use depending on the activity in issue. The following are some of the specific instances when we collect your information –

When you (or someone using your telephone line) make a telephone call or send a fax that uses our telephone network or connect to the world wide web, we keep a record of that call (including the number called) to enable MTL to charge for it. We also receive from other operators information about calls made over our network, where we need that information for connecting and billing purposes.
If someone abuses or damages the telephone network, for example by making offensive or nuisance calls, we may keep information relating to that abuse.
We have information about your use of our products and services (such as the amount of time you spend on-line), which we use to manage our network, and for billing. We may also use this information for marketing products and products and services but we will give the option to opt out of receiving this material.
If you enter into any of our competitions or promotions, we may ask for information about you, which will be made clear at the time you enter. We will also inform you of the purposes for which the information you provide may be used.
We may ask you from time to time about what use you make of the products and services we provide, what other products and services you would like us to provide in the future, and for other information, such as lifestyle data.
We collect information from visitors to our websites to help us to make improvements to the websites and to the products and services we make available. We know, for instance, how many visitors there are to each website, when they visited, for how long and to which areas of our website they went. We may share this information with our advertisers and to other companies which offer their goods or products and services on our websites. It helps to show these organisations how effective our websites are as sales channels for their products and services. You or any other individual cannot be identified from the information we share as the data is aggregated and anonymised.
We also make telephone numbers available on directory enquiry products and services unless customers have chosen to be ex-directory.
We may also monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about the products and services you order from us, and in order to meet our legal and regulatory obligations generally

What personal information do we collect about you from other companies and organisations?

We may receive personal information about you from other companies and organisations (for example, for marketing purposes) and we rely on these third parties to obtain your consent for us to use this information.

We receive information from other telecommunications operators about their customers to enable us to enter their details (together with our own customer’s information) in telephone directories.

How can I find out what personal information MTL holds about me?

If you want specific information i.e. copies of fault reports, bills and invoices etc then you must contact our Customer Services.

You may be requested to provide the following information, among others, so that we can process your request:

The relevant account number/s
The relevant telephone number/s
The relevant address/s
The date and time if requesting a call recording.

If you have any information such as reference numbers, dates and times of contact then please include them in your request.

How can I change the personal information MTL holds about me?

If the information we hold about you is inaccurate, please let us know and we will make the necessary amendments and confirm that these have been made.

What do we use the information for?

MTL or its lawful agents may use your personal information for a number of purposes including the following:

to provide our products and services, activities or online content and to deal with your requests and enquiries;
for service administration purposes, i.e. MTL may contact you for reasons related to the service, activity or online content you have signed up for, e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance);
to contact you about a submission you have made, including any content you provide.
to provide you with information about our products and services, activities or online content;
to personalise the way MTL content is presented to you
to use IP addresses to identify the location of users, to block disruptive use
to analyse and improve the products and services offered by MTL
to provide you with the most user-friendly navigation experience.
MTL may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
monitoring or recording of your calls, emails or SMSs may take place for business purposes to the extent permitted by law, such as for example quality control and training for the purposes of marketing and improving the products and services. However, in these situations, we will not disclose information that could be used to personally identify you.
to create products or products and services that may meet your future requirements and/or delivering targeted advertising to you within MTL’s various current and future web and wap portals

Where the MTL proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.

For how long does MTL keep personal information?

The time period for which we keep information varies according to what the information is used for. In some cases, there may be legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed or as long as is set out in any relevant contract you hold with MTL or the MTL's corporate retention policy (a database that defines which documents should be kept and for how long).

Some content submitted to, or shared with, MTL may be retained for prolonged periods of time or potentially indefinitely in the MTL's archives if it is necessary for historical or other similar purposes. Where possible, we will endeavour to inform you upfront or let you know at a later date where we are likely to keep content indefinitely or pass it onto an approved historical archive.

Does MTL disclose any of my personal information?

MTL does not distribute, disclose or transmit, sell any of your personal information to third parties unless;

expressly authorized by you
it is very necessary to enable MTL’s agents or contractors to perform certain authourised function e.g. debt collection or installation of a service
it is required to deliver the products and services requested by you.
it is necessary to pass on your data to a supplier who will deliver the product or service on order.
it clearly required and permitted by law for example under a court order, or in response to properly made demands, under powers contained in legislation.

As a normal part of our business we share with other communications companies information for connecting and charging for calls over each others networks. We may sometimes use other companies to provide products and services to you or to provide products and services to us. To enable them to do this, we may need to share your personal information with them.

We may provide information, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide information for the purpose of safeguarding national security.

If there is a change (or prospective change) in the ownership of MTL or any of its assets, we may disclose personal information to the new (or prospective) owner. If we do so, we will require them to keep it confidential.

In case MTL uses third parties to process your information, MTL shall require these third parties to comply strictly with its instructions and MTL requires that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way.

In all cases we will disclose the information to third parties consistent with applicable laws and regulations.

What about the security of my personal data?

We are serious about guarding the security of your personal information and the details of any transactions made. We take appropriate organisational and technical security measures to protect your data against loss, misuse, alteration, unauthorised access or disclosure or processing. We use a secure server to store the information you give us when you register or make an order. Any personal data you send us on line is securely encrypted.

As we make every effort to ensure security of our network and systems, we cannot guarantee security measure from hackers even though we periodically subject our site to stimulated tests and have developed comprehensive disaster recovery plans.

All users shall exercise caution when making a decision to disclose personal information to us. Please note that your billing account number is a sensitive piece of information, which can be used with your telephone number to find out information about your use of MTL´s products and services. Please be sure to keep this information safe, and do not share it with others. For access to information such as itemised billing and some business account and ordering products and services, extra proof of identity and authorisation may be needed.

Over and above what MTL does to safeguard your privacy and security on-line, there are a number of things you can do to protect yourself from Internet fraud:

Choose a password (letters and digits) you can remember but others will not guess, change it regularly and, if you do write it down, keep it somewhere safe and secure.
When you have finished your session on our website, make sure you prevent your details being seen by anyone that you do not wish to see them. So, if you have registered and logged in, remember to log off.
Clear any cache so there is no record of any transactions left on screen - both Netscape and Internet Explorer let you do this.
We also recommend you then close your browser so any history of the session is cleared.

The use of Cookies

When you visit our website we may store some information commonly known as a cookie on your computer which does not identify you personally, but provides MTL with usage data to recognise subsequent visits. A "cookie" is a text file which is allocated by our server to your personal computer (PC) when you visit our website. If you want to know more about cookies please go to www.allaboutcookies.org which explains how cookies work and how you can manage their use.

The type of information gathered is non-personal (such as: the IP address of your computer, the date and time of your visit, which pages you browsed and whether the pages have been delivered successfully. Apart from merely establishing basic connectivity and communications, MTL may also use this data in aggregate form to develop customised products and services - tailored to your individual interests and needs. Should you choose to do so, it is possible (depending on the browser you are using), to be prompted before accepting any cookies, or to prevent your browser from accepting any cookies at all. This will however cause certain features of the website not to be accessible. By assigning a unique data element to each visitor, the website is able to recognize repeat users, track usage patterns and better serve you when you return to the site and cookies do not extract other personal information about you such as name and address.

We do not store information regarding your telephone number, account or payment details in the

cookie, and this information cannot be accessed using it. Please note that as the cookie is based on your PC, we will not find it if you visit our websites using a different PC to the one you registered on.

Please note that during your visits to MTL websites you may notice some cookies that are not related to the MTL or the MTL's contractors. Other companies which advertise or offer their products or services on our website may also allocate cookies to your PC. The types of cookies they use and how they use the information generated by them will be governed by their own privacy policies and not ours. MTL does not control the dissemination of these cookies. You should therefore check the third party websites for more information about these.

All types of cookies can be removed from your PC but there may be some deterioration in the service you receive (for example, you may receive many pop up boxes containing the same advertisements or you may not be able to access a page you earlier personalised).

Your browser lets you choose whether to accept, not to accept or to be warned before accepting cookies. These settings can be found in the advanced preferences. In Internet Explorer 6 select: Tools menu / Internet options / Privacy. In Netscape 7.1 select: Edit menu / Preferences / Privacy and Security / Cookies. In Firefox select: Tools menu / Options / Privacy / Cookies. For removing the "Remember me" cookie, just unpick the box when you sign in.

Amendments to this Privacy Statement

MTL reserves the right to amend or modify this Privacy Statement at any time. When updates are made, the privacy policy version date will also be updated to reflect that a revision occurred. We encourage you to periodically reread this policy to see if there have been any changes that may affect you. If you do not agree to these changes, please do not continue to use MTL websites to submit personal information to the MTL.

Electronic Communications

MTL is not responsible for the proper and/or complete transmission of the information contained in the electronic communication or of the electronic communication itself nor in any delay in its receipt. Please also note that your electronic communication, like most if not all, non-encrypted communications may be accessed and viewed by other users without your knowledge and permission while in transit to us. For this reason to protect your privacy, please do not communicate information that you consider confidential to us and you may wish to use the phone numbers provided or visit our shops.

Intellectual Property Rights

You acknowledge that we own the intellectual property rights in and to the MTL website, and all products or services contained herein, and that the unauthorised use thereof is expressly prohibited. Any trademark registered by MTL, belongs to MTL. These Trademarks may not be copied, transmitted or used by anyone else unless authorised by MTL. Any reference to use of a product, service or process of a third party does not imply recommendation, approval or affiliation to the product, service or process by MTL

Passwords

If you have a password assigned by MTL you undertake to keep it secure in safe location and warrant that no one else shall use to access any products or services utilising your password, and you acknowledge further that you are responsible for ensuring that no unauthorised access to the products and services is obtained using your password, and that you will be liable for all such activities conducted pursuant to such use, whether authorised or not.

Termination

MTL may, in its sole discretion, at anytime suspend or terminate this policy, the operation of its website or any products and services provided in its website, without prior Notice.

General

Navigation of MTL’s website with its terms and conditions and any transactions arising there from shall be governed in accordance with the laws of the Republic of Malawi, and you shall submit to the jurisdiction of the Malawi Courts.

If any provision of this policy is determined to be illegal or unenforceable by any court of competent jurisdiction, then such provision shall be deemed to have been deleted without affecting the remaining provisions of the terms and conditions.

MTL’s failure to exercise any particular rights or provision of this policy shall not constitute a waiver of such right or provision, unless acknowledged and agreed to by us in writing.

The provisions of this policy shall only be for the benefit of MTL and may be waived by us in our discretion.

Contacting MTL about this Privacy Policy

If you have any questions or comments about this Privacy Policy please contact:

The Chief Executive Officer

Malawi Telecommunications Ltd

P.O. Box 537

Blantyre

MALAWI

Tel: + 265 1 846 977

Fax: + 265 1 846 445

Customer Care: +265 1 870 278

E-mail: info@mtl.mw