We respect your right to privacy, it is very important to us, and we take the protection of your privacy and ensuring the security of your Personal Data very seriously.
We are committed to the fair and transparent Processing of your Personal Data in line with the provisions of the Nigeria Data Protection Act (NDPA) and other applicable laws. This Privacy Notice describes how we Process your Personal Data, explain 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.
Who are we?
In this privacy notice “MTNF”, “we”, “our” and “us” refers to MTN Nigeria Foundation Limited (“MTNF”) a limited company, incorporated in the Federal Republic of Nigeria with registration number 602002 and its principal office at MTN Plaza, Ikoyi, Lagos State .
Who does this notice apply to?
This notice applies to individuals that are:
- any person(s) who is applying for the MTN Scholarships (“applicants”), including potential applicants to the extent MTNF Processes your Personal Data;
- any person(s) who uses our website, mobile applications or any products or services (“users”);
- all suppliers, contractors, partners and service providers of MTNF (“suppliers”) including potential suppliers to the extent MTNF Processes your Personal Data;
- all visitors of MTN premises whose details are captured via our visitors’ register, visitors management system, CCTV cameras etc; and
Important terms you need to understand when reading this notice?
| 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 MTNF is required to comply by applicable authorities in the jurisdictions in which MTNF operates or where Personal Data is Processed by MTNF 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. |
| NDPA | Means the Nigeria Data Protection Act 2023 |
| NDPC | Means the Nigeria Data Protection Commission |
| Personal Data | Means any information relating to a Data Subject. Examples of “Personal Data” includes, but is not limited to, the following:
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| 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, organisation, 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 which 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 behaviour 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. |
What Personal Data does MTNF collect and use?
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 is strictly for MTNF scholarship purpose only.
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:
- Biodata: which may include your surname, firstname, middlename, gender, dob, marital status.
- Physical Health Details: We collected your specific information such as physically challenged, physically challenged brief, etc. address, postal address, telephone number);
- Geographical Location Details: We collect your geographic information such as state of origin, LGA, state of residence, LGA residence, email, phone number.
- Educational and Institution Details: we collect applicant specifics information such institution name, institution type, faculty, department, course, course duration, matric number, current academic level, who pays fees, CGPA, study mode, institution location.
- Previous Scholarship Details: we collect information like receipt scholarship, scholarship award, year of admission, mode of admission and reg number
- web browsing and application usage: we collect your Personal Data when you visit our website or use our mobile applications. This may include, your IP address, browser type; operating system; mobile carrier; your ISP; URLs of sites from which you arrive or leave the website and mobile applications and sites that have our platform technology embedded; time you spend on our website or mobile applications; links or advertisements you see; purchases made through our website; first party cookies and other webtracking technologies. We may also collect information identifying or related to equipment accessing our networks including the software, configuration, equipment type and other unique identifiers (such as your username and password). Third party cookies will also be collected from our selected marketing technology partner(s), third party websites and applications.
- Cookies: We use cookies to help you navigate efficiently and perform certain functions. You will find detailed information about all cookies on our website
The cookies that are categorized as "Necessary" are stored on your browser as they are essential for enabling the basic functionalities of the site.
We also use third-party cookies that help us analyze how you use this website, store your preferences, and provide the content and advertisements that are relevant to you. These cookies will only be stored in your browser with your prior consent.
You can choose to enable or disable some or all of these cookies but disabling some of them may affect your browsing experience.
Where does MTNF collect my Personal Data from?
In most circumstances we collect Personal Data directly from you, for instance, when you apply for scholarship , visit our website or premises, interact with our staff or enter into business relationship with us.
In some instances, however, we will also collect your Personal Data indirectly from applicant through MTN Scholarship application portal.
For what purposes does MTNF use your Personal Data?
MTNF will use your Personal Data for purposes of:
- For Applicant Screening: We used the information for screening scholarship candidates or applicant.
- For Selecting Applicants: We used the information for selection of applicants for purpose scholarship program
- For the Award of Scholarships: We process your personal data for purpose of awarding scholarships.
- Customer service: we Process your Personal Data to provide you with customer services including to respond to any question, query, requests, concerns or complaints you may have about MTNF employees or our Processing activities.
MTNF will not further Process Personal Data for any purpose that is incompatible with the original purpose that the Personal Data was collected for unless:
- such further Processing is authorized in terms of applicable data privacy laws;
- we have obtained your consent to the further Processing;
- the further Processing is necessary to comply with an obligation imposed by Regulatory Requirements or for conducting proceedings in a court or tribunal; or
Is MTNF allowed to Process my Personal Data?
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 MTNF 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:
- Performance of a contract: this is when the Processing of your Personal Data is necessary to conclude a contract or perform our obligations under a contract entered into with you
- Legal obligation: this is when we are required to Process your Personal Data to comply with a legal obligation
- Vital interests of the data subject or another natural person: the Processing is necessary to protect the vital interests of the relevant Data Subject or of another natural person
- Public Interest: the Processing is necessary for the performance of a task carried out in the public interest.
- Your consent: in some cases, we will ask you for specific permission to Process some of your Personal Data. This consent may withdrawn at any time.
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:
- You have given explicit consent to the Processing of your Sensitive Personal Data for one or more specified purposes. You may withdraw such consent at any time;
- Processing is necessary to protect your vital interests or of another natural person and you are physically or legally incapable of giving consent;
- Processing relates to Sensitive Personal Data which was intentionally made public by you;
- Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;
- Processing is necessary for scientific or historical research purposes or statistical purposes provided such Processing is proportionate to the aim pursued, MTNF respects the essence of the right to data protection and MTNF provides for suitable and specific measures to safeguard your fundamental rights and the interests.
- Processing of Personal Data related to criminal behaviour is obtained and used in accordance with Local Regulatory Requirements.
Is it mandatory to provide MTNF the Personal Data asked for?
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 carry out needed verification exercise, which is essential for the application process based on the scholarship selection criteria. Which may impact your chances of being selected in the MTN Foundation Scholarship
How long does MTNF keep my Personal Data for?
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:
- retention of the Personal Data is required or authorized by relevant laws;
- you have consented to the retention of the Personal Data; or
- the Personal Data is required for historical, statistical or research purposes and provided that we have established appropriate safeguards against the Personal Data being used for any other purposes.
We will ensure that Personal Data which is no longer required, or which we are no longer authorized to retain, is as soon as reasonably practicable, de-identified or destroyed through secure means, alternatively through permanent erasure by appropriate and effective mechanisms.
Does MTNF transfer my Personal Data to third parties?
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:
- Implementing Partners: We transfer your Personal Data to our third-party implementing partners in charge of project managing the MTN Foundation Scholarship implementation. These third-party partners are responsible for screening, selecting and shortlisting applicants for the award of the MTN Foundation Scholarships. As well as managing the scholars awarded the MTN Foundation Scholarship
- Test Partners: We transfer your Personal Data to our third-party Test Partner who in charge of conducting online proctored test for applicants applying for the MTN Foundation Science and Technology Scholarship
- Our service providers: We transfer your Personal Data to our third-party service providers, such as our (IT) systems providers, our hosting providers, consultants (such as legal advisers) and other goods and services providers. These providers Process your Personal Data on behalf of MTNF in terms of a binding agreement with appropriate security safeguards. MTNF will only transfer Personal Data to such a service provider when they meet our strict standards on the Processing of data and security. We only share Personal Data that allows our service providers to provide their services and they are not allowed to Process your Personal Data for any other purpose.
- If we are reorganized or sold to another organization: MTNF may disclose Personal Data in connection with the sale, assignment, or other transfer of the business to which the data relates.
- Courts, tribunals, law enforcement, or regulatory bodies: MTNF may disclose Personal Data in order to respond to requests of courts, tribunals, government, or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.
- Audits: disclosures of Personal Data may also be needed by our auditors including to perform financial audits, data privacy or security audits and/or to investigate or respond to a complaint or security threat.
- Insurers: our business requirements mean that we carry significant insurance cover in respect of business activities. There are several different participants in the insurance market (e.g., brokers, insurers, and reinsurers, as well as their professional advisors and other third parties involved should there be a claim). Some of these insurance market participants will require that we disclose Personal Data about you to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance products, where there is a claim that you are relevant to and to allow the insurance market participants to comply with their legal and regulatory obligations. Some of these insurance market participants will handle this information on our behalf (like our service providers described above), but others will want to Process information about you independent of us.
- Other third parties: we may share information with other third parties who use MTNF platforms / systems to advertise their product. However, the Personal Data collected is anonymized and/or aggregated prior to sharing with such third parties.
Does MTNF transfer my Personal Data internationally?
Yes, MTNF transfers Personal Data outside of Nigeria but only if such transfers are permitted in terms of the provisions of the NDPA, other applicable laws and or guidelines as may be issued by the NDPC..
MTNF 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.
MTNF also transfers certain Personal Data outside of Nigeria 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 to binding data transfer agreements or by ensuring there are adequate data privacy laws, which requires the relevant third party to adhere to the data handling and data protection requirements, acceptable to MTNF.
How does MTNF secure my Personal Data?
MTNF 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:
- accidental loss of, damage to, or unauthorized destruction of your Personal Data;
- unlawful or unauthorized access to your Personal Data; and
- unlawful or unauthorized Processing of your Personal Data.
As part of its processes, MTNF 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.
How does MTNF handle Personal Data Breaches?
While MTNF implements reasonable measures to prevent or reduce the likelihood and impact of Personal Data Breaches, this risk can’t be completely eliminated. If MTNF becomes aware of or reasonably suspects a Personal Data Breach has occurred or that the integrity or confidentiality of Personal Data has been compromised, MTNF adheres to its incident management Policies, Procedures and supporting documents governing the handling and reporting of Personal Data Breaches. MTNF will report personal data breaches to the Data Privacy Regulator within 72 hours of knowledge of such breach as required by the provisions of the NDPA.
What are my rights?
If MTNF Processes Personal Data about you, you have the following rights:
- Access and correction: you have the right to access the Personal Data retained by MTNF. This is sometimes called a ‘Data Subject Access Request’. If we agree that we are obliged to provide Personal Data to you, we will provide it to you free of charge. Before providing Personal Data to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your Personal Data. If the Personal Data we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the Personal Data.
- Object to Processing: you have the right to object to us Processing your Personal Data, on grounds relating to your particular situation, under certain circumstances (including to receiving direct marketing from us). For example, if we are Processing your Personal Data on the basis that is necessary for purposes of our or a third party’s legitimate interest or in the public interest. You may also object if you believe there is no legal basis for us to Process your Personal Data anymore.
- Withdraw consent: you also have the right to withdraw your consent at any time and we cease Processing your Personal Data unless there is an alternative legal basis to continue Processing your Personal Data. We will advise you if we intend to continue Processing your Personal Data in these circumstances.
- Disposal / Restrictions: in addition, you may have rights to have your information deleted / destroyed if we are keeping it too long or have no legal basis to Process it. You may also request that the Processing of your Personal Data is restricted in certain circumstances.
- Receive information: You have the right to receive your Personal Data in a commonly used and machine-readable format and the right to transmit these data to another Data Controller when the processing is based on (explicit) consent or when the processing is necessary for the performance of a contract.
- Object Automated Processing: You have the right to object to profiling and automated decision-making, and to opt-out of such processing. If you choose to exercise this right, we will ensure your request is respected.
- Lodge complaints: you have the right to lodge a complaint regarding the way your Personal Data is being Processed with MTNF or if you believe there has been a breach of MTNF privacy policies and/or data privacy laws.
You can make a request or exercise these rights by contacting MTNF at MTNF Data Protection Officer (DPO) DPONigeria@mtn,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
Contact us
If MTNF Processes Personal Data about you, you have the following rights:If you have any questions or concerns regarding this Privacy Notice and would like further information about how we protect your information and/or when you want to contact your local Data Protection Officer (DPO), please email us at DPONigeria@mtn.com or visit the MTNF Nigeria Foundation Limited (“MTNF”) at its principal office at MTN Plaza, Ikoyi, Lagos State.
Changes to privacy policy
MTNF may modify this Privacy Notice from time to time to reflect our current privacy practices. When we make changes to this notice, we will revise the “effective” date at the top of this notice