We respect your right to privacy, it is very important to us, and we take the protection of your privacy and ensure the security of your Personal Data very seriously.
We are committed to the fair and transparent Processing of your Personal Data. This Privacy Notice describes how we Process your Personal Data, explains your rights in relation to the Personal Data we Process, and states our commitment when Processing your Personal Data in a compliant, ethical, and secure manner.
In this privacy notice “MTN”, “we”, “our” and “us” refers to Lonestar Cell MTN, a public limited liability company, incorporated in the Republic of Liberia with its Head office at LBDI Building, Oldest Congo Town, Monrovia, Liberia.
This notice applies to individuals that are:
|Data Subject||Means an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. It shall also include any additional persons afforded data privacy rights and protection of Personal Data in terms of Applicable Data Privacy Law(s).|
|Local Regulatory Requirements||Legal, statutory, regulatory, license conditions rules, guidelines, Ministerial/National Security orders or directives, and Directives relating to Public safety (where applicable) and Data Sovereignty*-related requirements with which MTN is required to comply by applicable authorities in the jurisdictions in which MTN operates or where Personal Data is Processed by MTN or on its behalf.
*Data Sovereignty relates to the laws and governance structures that Personal Data is subject to, due to the geographical location of where it is Processed.
|Personal Data||This means any information relating to a Data Subject. Examples of “Personal Data” include, but are not limited to, the following:
• a name;
• any identifying number, symbol;
• contact information (e.g. e-mail address, postal address, telephone number);
• location data or physical address;
• online identifier or unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number or other assignment to the person;
• the biometric information of the Data Subject;
• the personal opinions, views or preferences of the Data Subject;
• correspondence sent by the Data Subject that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
• the views or opinions of another person about the Data Subject;
• the name of the Data Subject if it appears with other Personal Data relating to the Data Subject or if the disclosure of the name itself would reveal information about the Data Subject; and
• Sensitive Personal Data.
|Processing||Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, including collection, receipt, recording, organization, structuring, collation, storage; adaptation or alteration, updating, retrieval, consultation, use, dissemination, disclosure by means of transmission; or otherwise making available, alignment or combination, merging, restriction, erasure, destruction, and/or degradation.|
|Sensitive Personal Data||A sub-set of Personal Data that is considered more sensitive than other categories of Personal Data. Sensitive Personal Data includes but is not limited to Personal Data revealing a Data Subject’s racial or ethnic origin; political opinions or persuasions; religious or philosophical beliefs; trade union membership; criminal behavior relating to the alleged commission of a crime or proceedings relating to the alleged commission of a crime; genetic data; biometric data; data concerning health; and/or data concerning a Data Subject’s sex life or sexual orientation.|
To run our business, we may be required to collect, use, store and otherwise Process your Personal Data. The Personal Data that we may collect and Process can vary depending on the MTN products and services that you use, contract for or that you supply to us; how you may be using or delivering those products and services; and the means by which you may be interacting with us.
We will only collect the Personal Data of yours that is adequate, relevant and limited to what is needed in relation to the specific purposes for which we are collecting it, as described in this privacy notice.
The Personal Data collected and Processed by us may include:
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In most circumstances we collect Personal Data directly from you, for instance, when you buy or use any of our products or services, visit our website or premises, interact with our customer services departments, or enter into a business relationship with us.
In some instances, however, we will also collect your Personal Data indirectly from third parties, such as from:
MTN will use your Personal Data for the purposes of:
MTN will not further Process Personal Data for any purpose that is incompatible with the original purpose that the Personal Data was collected for unless:
We are allowed to Process your Personal Data, so long as we have a legal basis to do so (i.e. there is a justification to Process your Personal Data in terms of laws applicable to MTN and/or our policies permit such Processing). When we Process your Personal Data, we will rely on one of the following legal bases, as appropriate, having regard to the purpose of Processing:
In those instances when we Process your Sensitive Personal Data, we will rely on one of the following legal bases as appropriate having regard to the purpose of Processing:
It is not mandatory for you to provide any Personal Data to us. However, failing to provide certain Personal Data to us, particularly where that Personal Data has been requested by us may impact our ability to, amongst other things:
to allow you access to our premises or buildings
We will not retain your Personal Data for any longer than is necessary for achieving the purpose(s) for which the Personal Data is Processed, unless:
Yes, we do share Personal Data with affiliated third parties, as necessary for our legitimate business needs, to carry out your requests, and/or as required or permitted by law. This would include:
Yes, MTN transfers Personal Data outside of Liberia but only if such transfers are permitted in terms of Local Regulatory Requirements.
MTN may transfer your Personal Data to other entities within the MTN group of companies. All MTN entities are bound by binding corporate rules which ensures that the MTN entity receiving your Personal Data protects your Personal Data in accordance with those binding corporate rules.
MTN also transfers certain Personal Data outside of Liberia to third parties working with us or on our behalf for the purposes described in this Privacy Notice. When transferring Personal Data internationally to third parties we ensure your Personal Data will continue to be protected for example, by entering into binding data transfer agreements or by ensuring there are adequate data privacy laws, which require the relevant third party to adhere to the data handling and data protection requirements, acceptable to MTN.
MTN secures the integrity and confidentiality of the Personal Data in its possession or under its control by implementing appropriate, reasonable technical, physical, and organizational measures to prevent:
As part of its processes, MTN takes reasonable measures to regularly identify and assess all reasonably foreseeable internal and external risks to Personal Data in its possession or under its control and implements reasonable and appropriate technical, physical and organizational security measures to protect against the identified risks.
While MTN implements reasonable measures to prevent or reduce the likelihood and impact of Personal Data Breaches, this risk can’t be completely eliminated. If MTN becomes aware of or reasonably suspects a Personal Data Breach has occurred or that the integrity or confidentiality of Personal Data has been compromised, MTN adheres to its incident management Policies, Procedures, and supporting documents governing the handling and reporting of Personal Data Breaches. MTN will report personal data breaches to the Data Privacy Regulator within 72 hours of knowledge of such breaches.
If MTN Processes Personal Data about you, you have the following rights:
You can make a request or exercise these rights by contacting MTN Risk & Compliance at email@example.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and internal policies.