INDIVIDUAL CONSUMER CODE OF PRACTICE

i. INTRODUCTION:
At SpeedyLink Communications, we are committed to delivering high-quality, reliable, and customer-focused fixed internet services across Abeokuta, Ogun State, Nigeria. As a responsible Internet Service Provider (ISP), we recognize the importance of upholding industry best practices, regulatory compliance, and customer rights while ensuring seamless connectivity and satisfaction for our users.

This Individual Consumer Code of Practice outlines Provision of information to consumers, Advertising and Representation of Service, Consumer Billing, Charging, Collation and Credit Practices, Consumer Obligations, Protection of Consumer Information, Compliant handling in accordance with the Individual Consumer Code of Practice Regulation, 2024 of the Nigerian Communications Commission (NCC). It serves as a transparent framework to inform customers about their rights, our responsibilities, and the standards they can expect when engaging with our services.

Our core objectives in implementing this Code are to:
• Ensure clarity and fairness in our dealings with customers.
• Promote transparency in service provision, pricing, and complaint resolution.
• Provide a structured and accessible mechanism for handling customer inquiries and disputes.
• Comply with all applicable laws, regulations, and directives set forth by the NCC.
• Uphold the highest standards of service quality, reliability, and customer care.

This Code applies to all our service offerings, - Fixed Wireless Internet, Hotspot Internet, Unlimited Service Plans, Dedicated Unlimited Services, and Data-Capped Plans. It sets forth the procedures for service provision, billing, complaints handling, service guarantees, and customer support, ensuring that every subscriber experiences a fair and efficient resolution process whenever necessary.

By adhering to this Individual Consumer Code of Practice, SpeedyLink Communications reaffirms its dedication to excellence, accountability, and consumer protection, in line with the regulatory expectations of the Nigerian Communications Commission.

ii. CLAUSE - DEFINITION OF TERMS AND GOVERNING LAWS

In this Individual Consumer Code of Practice (as defined herein), unless there is something in the subject matter or context inconsistent therewith, the following terms shall have the respective meanings ascribed below:

• Network Availability:
This is defined as the aggregate reachability of all end points (that is, Internet access routers) on SpeedyLink Communications’ Network.

• Service Availability:
This is defined as the ability to exchange IP packets with the SpeedyLink Communications Network via the internet access router port(s).SpeedyLink Communications guarantees a minimum service availability of 97.5% per calendar month. This means that, under normal operational conditions, the Service Provider will ensure that the internet service is available to the Customer for no less than 97.5% of the total time in any given month.

• Local Access:
This is defined as any last mile network or other network components connecting the Customer to SpeedyLink Communications Network.

Service Unavailability: This is defined as periods during which (i) the Network or Service is unavailable. Service Unavailability is calculated from trouble ticket timestamps in accordance with the following formula: Service Unavailability= (Total Time Open - Monitoring Time - Customer Time)

• Total Time Open:
This is the period of time from when SpeedyLink Communications opens a trouble ticket upon observing a trouble condition or following the report of a problem by Customer, until the time that the ticket is closed.

• Monitoring Time:
This is the length of time a trouble ticket remains open following notification to Customer by SpeedyLink Communications that service has been restored and is operating in accordance with agreed specifications, without any response from customer, up to a maximum of twenty-four (24) hours.

• Customer Time:
This is all period(s) during which, following the opening of a trouble ticket, SpeedyLink Communications is unable to take remedial action due to Customer-controlled conditions; such as failure or delay in providing access to Customer facilities, failing to provide responses SpeedyLink Communications’ inquiries or failing to take remedial action in relation to the Customer controlled equipment requested by SpeedyLink Communications. Customer Time shall not include any Monitoring Time as defined above.

• Company:
The internet service provider-SpeedyLink Communications that provides fixed wireless internet services to customers

• Customer/ Subscriber/ Consumer:
An individual or organization subscribing to our fixed wireless internet services.

• Service Level Agreement (SLA):
A formal commitment detailing the performance standards, uptime guarantees, and support response times.
• Complaint:
Any expression of dissatisfaction with our internet services or processes.

• Maintenance Window:
Pre-scheduled periods during which service may be temporarily disrupted for maintenance purposes.

• Threshold:
The number of minutes of down time will be stored cumulatively. A threshold of 100 hours of service unavailability will then be calculated and compensated.

• Compensation:
The refund shall be calculated based on the Customer’s next subscription due date once the total downtime reaches 100 hours. Instead of a monetary refund, the compensation for downtime during the affected month will be provided cumulatively, with a 24% compensation, by receiving a voucher or by extending the due date for re-subscription upon surpassing the specified threshold. The total downtime each month will be communicated on the first week of the next month.

• Exclusions:
This SLA does not apply to interruptions or performance degradation caused by the following:
1. Scheduled or emergency maintenance as communicated by SpeedyLink Communications.
2. Force majeure events, including but not limited to natural disasters, war, or other events beyond the control of the Internet Service Provider.
3. Customer’s hardware, software, or network issues not related to SpeedyLink Communications’ infrastructure.
4. Customer's failure to comply with the Service Provider’s recommended configurations or usage policies.
5. Customer's acts or omission which damages the equipment or infrastructure.

• Service Fees and Validity:
The service fees payable every 30 days period is the sum based on the current price per bandwidth. The customer shall ensure to pay the full service fees in addition to all taxes required to be lawfully paid. The service fee may be subject to review during the service term to give effect to any reasonable adjustment for increase in the cost for providing the services to the customer occasioned by third parties increase of cost, inflation and devaluation of currency.

• Suspension of service:
The services provided by Speed link communications to lease customers will be automatically suspended when the customer fails or neglects to pay for the services as and when due. A failure to pay or subscribe for a continuous period of two months will amount to a breach and the service provider shall have right to retrieve its leased equipment upon a 30 days written notification.

• Cancellation & Refund:
There is a 30-day refund policy for customers who request a refund for payments made to SpeedyLink Communication. This policy applies to any refund requests initiated for reasons deemed by the customer. The refund process require additional time due to the necessary paperwork and administrative procedures involved in reconciling our books. • Monthly Service Availability Reporting:

A monthly service availability report, is a summary of uptime, downtime, and any other relevant metrics. These reports will be made available by the first week of the following month and will include the calculation of service availability percentage, any downtime occurrences and their causes, and the total duration of downtime.

• Limitation of Liability:
SpeedyLink Communications' liability under this SLA is limited to the total service fees paid by the Customer for the month in which the downtime occurred. In no event shall the company be liable for any consequential, incidental, or indirect damages arising from service interruptions or failure, or failure of the customer to pay.

• Agreement Acceptance and Governing Law:
By signing, using the internet services or agreeing to this SLA or making payment, both parties agree to the terms and conditions outlined above, and acknowledge that they have the necessary authority to enter into this agreement.The validity and interpretation of this Agreement shall be governed exclusively by the Laws relating to service level agreements operational and applicable in Nigeria.

• Use of Equipment:
• Permitted Use
The Customer agrees to use the equipment only for the intended purpose of accessing the fixed Wireless internet service within the agreed location installed by Speedylink Communications for the customer.

• Prohibited Use
The Customer shall not use the equipment for any unlawful or unauthorized activities, including but not limited to: tampering with the equipment, attempting to alter or modify it, or using it in any manner that violates local laws or the terms of service of Speedylink Communications. Customers/ subscribers are not allowed to use the Speedylink Communications' network to disseminate, cause to be disseminate or access such content. Our network should not be used to disseminate any information which directly or indirectly cast aspersion on a religious, political, group, ethnic group or race. The Speedylink Communications' network should not be used for any pornographic article, any obscene article within the meaning of section 233 of the Criminal Code Act, Cap. 77, Laws of the Federation, 1990.


1. PROVISION OF INFORMATION TO CONSUMERS
SpeedyLink Communications provides complete, accurate and up- to-date information about its services in clear language across all communication channels. This information to consumers includes details on fixed wireless internet service offerings, service plans, signup packages, service contracts, SLA and terms and conditions.

Response to customers will be done within 96 hours during which requests for information on our services shall be provided free of charge, including the following information on (a) Current service plans arrangements, rates, terms and conditions for all services offered to the public, at our office and website ;

(b) Fixed wireless internet connection test (Link Budget and Site survey).before signup of customer.

a. Description of Service
1. Pre-Contractual Disclosure
Prior to the execution of any service contract, SpeedyLink Communications shall provide a full and clear description of the proposed Fixed Wireless Internet service. Descriptions shall avoid the use of technical jargon unless such terms are clearly defined and explained.

2. Disclosure of Service Requirements
In the event where the internet service delivery requires additional equipment, services, or specific conditions (such as line-of-sight, signal strength, etc.), consumers shall be expressly informed of these requirements prior to entering into the contract.

3. Service Plan Details and Installation Timelines
Consumers shall be informed of the available service plans, bandwidth options, applicable price ranges (including considerations for the number of connected devices), and the expected installation timelines based on the nature and scale of the installation project.

4. Service Quality, Refunds, and Compensation
The Company shall clearly communicate provisions for refunds, compensation, or other remedies in situations where the agreed quality of service is not delivered. These shall align with SpeedyLink’s30-Day Refund Policy and include a description of the dispute resolution process for addressing service-related issues.

b. Service Contract
1. Outright Purchase and Lease Models
Where services are offered under either an Outright Purchase or Lease contractual arrangement, the Company shall provide detailed information regarding the specific terms applicable to each model. These shall include:

(a) A description of the structure of contract and possible installment payment and features of each package, stating clearly whether the radios, routers, poles, cables, or other installation components are sold or leased. The price of such equipment shall be provided separately and distinctly from the recurring monthly service subscription charges.
1. Outright Purchase Option: A one-time equipment cost of NGN 220,000.00.

2. Lease Agreement Option: An initial lease fee of NGN 110,000.00, renewable annually at NGN 60,000.00.

(b) For customers who already own compatible radio devices, SpeedyLink Communications shall charge a one-time Connection and Configuration Fee of NGN 20,000.00. These customers shall still be entitled to effective internet performance, technical support, routine maintenance, complaint resolution, and administrative assistance.

2. Fee and Tenor Adjustments
All fees, pricing structures, and tenors relating to equipment purchases, lease agreements, connection charges, and other service-related costs are subject to periodic review and adjustment by the Company, based on prevailing market conditions and corporate decisions.
However, SpeedyLink Communications shall ensure that consumers are provided with reasonable prior notice of any such changes before implementation.

3. Plan Migration and Bandwidth Modification
Consumers requesting a bandwidth upgrade, downgrade, or migration between service plans shall not be charged any administrative or migration fees. Only the subscription amount applicable to the new plan shall be payable. The Company shall provide complete and transparent information regarding all applicable terms, including any changes in service scope, performance expectations, or other impacts.

c. Pricing Information
Before a service contract is entered into with the customer, the SpeedyLink Communications shall inform the consumer of the following —
(a) the nature of internet service offered-Fixed Wireless and the process of determining connectivity as well as applicable cost of installation subject to the preferred contract type, scope of project, including the rates/bandwidth to be determined upon evaluation of the number of devices to be used by the customer;

(c) each part of the cost of an applicable charge, and the method of its calculation(one-off and recurring cost) ;

(d) the frequency of the charge-monthly (30days cycle) except otherwise communicated subsequently for other plans

(e) In the event of changes in price/ rates, the circumstances of such changes would be communicated officially within 4-8 weeks via our company phone number/WhatsApp or email.
Other cost apart from the recurring cost would include a stand-alone installation fee based on the preferred service contract. While the company may allow for a onetime payment for outright customers, customers on lease agreement are allowed to migrate to become outright customer through an installment70:30 payment model. In the event, where a lease customer wishes to renew his contract, such would be required to pay for the yearly renewal after the initial 2year contract period.

Note: All fees and tenors stated herein are subject to review and adjustment based on market realities and corporate discretion. In such instances, prior notice shall be provided to affected consumers before any changes take effect.

d. Contract terms and Termination
While the company seeks the continual patronage of customer, either party may terminate this agreement with 30 days' written notice. The outright customer is at will to suspend subscription or terminate the contract having owned the radio equipment, however the lease customer is unable to suspend for up to two months or use the company’s radio with another internet service provider (ISP), since the company owns the radio and can be terminated after two months of redundancy. To this end, a prior notice would be sent to the customer explaining this need for radio retrieval. In the event a customer relocates to another area that cannot be connected the termination of contract would take effect.

All hardware (equipment) on lease remain the exclusive property of SpeedyLink Communications and shall be retrieved upon 7 days of notice to the customer; in the same condition it was provided except for reasonable wear and tear. The customer shall grant all access required for the retrieval; as denial of access shall amount to a breach of rights, which is actionable. The customer is under obligation to protect the equipment in his custody and shall be liable for a total replacement or repair in the event of any damage. Speedylink communications will not be deemed liable for any service impairment or loss of functionality due to any damage occasioned by the acts or omission of the customer.

e. Product Warranties and Maintenance
Prior to entering into a contract the Company provides information about the warranties on purchased installation equipment (radios and routers) for up to 12 months. Customers are entitled to repair or replacement of defective hardware within the warranty period, provided the damage is not due to misuse, negligence, or third-party tampering. The said device can be dropped off by the customer at our office or retrieved by a staff. In the case of repairs, a reasonable timeline would be communicated to the customer and compensation (with a shift in the due date of subscription or subscription voucher) would be given to the customer for time lost during repair.
Maintenance services, including diagnostics and performance checks, are available under both outright and lease contract.

f. Fault Repairs and Service Interruption
(1)In the event of faulty equipment, the customer shall reach out to the company’s customer care staff promptly and the technical staff would retrieve the said device upon availability of the customer. The customer care line would be reached at any time of the day to report faults.

(2)The Company shall comply with the relevant fault repair standards set out in the Quality of Service Regulations issued by the Commission.

(3) The company shall endeavor to give advance warning of anticipated service disruptions or planned outages, including details of the disruption or outage, the services and service areas affected and any applicable compensation or other remedies.

(4) Where there is a disruption of service that is caused by a force majeure, the company shall notify its consumers where possible and shall endeavor to rectify the fault within such period of time as may be reasonable in the circumstances.

(5) Where there is a service disruption as determined by the Quality of Service Business Rules, the company shall publish such outage notice to the public, outlining the extent of disruption and remedial measures it intends to take. In line with public transparency, the company shall send all customers periodic monthly service availability report on the first week of every month.
The company shall maintain robust procedures for fault detection, escalation, and resolution. Upon detection or notification of a fault, the Company shall:
• Acknowledge the complaint and service interruption within 2minutes-60 minutes communicate to all stakeholders (customers ,in-house engineers, upstream suppliers, etc.) for immediate remediation.

• Monitor, resolve or provide a status update within 30 minutes-24 hours, depending on the nature of the fault.

• Inform customers in advance of any planned maintenance that may disrupt serviceavailability.

• Offer compensation or service credit for prolonged unplanned service outages beyond our given SLA timeframe (2.5% of total hours in a month), in accordance with the Company’s Service Level Agreement-97.5%,.

g. Subscription of Service
This offers a transparent, fair, and consumer-friendly subscription services to all our customers.A number of our offerings require radios and routers to connect to our service offerings except the hotspot.The company provides customers and subscribers with comprehensive details about their service plans, including the following:
• Plan names
• Pricing
• Validity periods(30 Days or otherwise stated or agreed)
• BandwidthSize based on the number of devices to be used (1-10Mbps & 20 Mbps+)
Simplification of Bandwidth Plans:
Plan names
1. Dedicated Unlimited Data Plan
2. Unlimited Data Plan
3. Data Cap+ FNW(Night and Free Weekend)
4. Hotspot

• Unlimited Data Plan: Six Bandwidth plans for Unlimited plans - on Point to Multipoint(PTMP) within 1-10 Mbps
• Dedicated Unlimited Data Plan: Dedicated Bandwidth plan- Point to Point(PTP) above 20Mbps
• Data Cap+ FNW(Night and Free Weekend): The Data Cap+FNWis a variation of unlimited and hotspot offering exclusive for unlimited customers
• Hotspot:Hotspot offering are location based installation made by the company and customers require no radio devices to connect.

Payment for Subscription:
Consumers may subscribe to SpeedyLink Communications' services by making payment through the official bank account details provided in the initial service quotation or communicated via the marketing and customer care staff/channel. In addition, the Company may designate third-party payment platforms or channels, which will be expressly communicated to the consumer for the purpose of facilitating subscriptions.
By proceeding with payment for any service, the consumer is deemed to have accepted the applicable terms and conditions governing the service.

Installation/Subsequent renewal:
For new customers, an initial bandwidth allocation of 1–2 Mbps is provided during the first month of service. The cost of this bandwidth shall be deducted from the overall subscription fee as indicated in the service plan. Service activation occurs upon successful installation and configuration of the selected service plan by company’s technical team. Consumers may renew or modify their service subscription at any time, subject to the provisions outlined in the service agreement and any applicable pricing or upgrade conditions.
Upon payment, consumers are required to share proof of payment (receipt or transfer confirmation) with the Customer Care staff via the Company’s official communication channel (e.g., WhatsApp line). Once payment has been verified, service activation or reconnection will be processed accordingly.

2. ADVERTISING AND REPRESENTATION OF SERVICES
SpeedyLink Communications shall comply with the advertising standards established by the Advertising Practitioners Council of Nigeria, and any other applicable laws or standards, in addition to the rules regarding the advertising or other promotion of communications services.

a. Availability of services
(1The Company shall publish in advertising materials the availability of its fixed wireless internet service, based on her current geographical or technical limitations on the availability of the service to consumers which —

(a) affect the recommended quality of internet service ; and are known to the company.

(2) the company shall publish in any advertising materials and communication medium which promote a fixed wireless internet service offer, any limitations such are locations outside the said locations on the website and its medium in the offer which restrict it —

(a) to a particular area based on topographic and technological limitations;
(b) to about 5km radius to her particular BTS(Obada, Asero and Adigbe Repeater Stations respectively), within Abeokuta, Ogun state, Nigeria ;
(c) to a 24 hours 7 days a week; or
(d) through the limited availability of equipment and facilities or other materials and topographical standards;

b. Advertising of packaged services
• When advertising an internet service as part of a package, SpeedyLink shall ensure that all components of the advertised package are available and deliverable to the consumer as presented.
• If any component of a service package is unavailable, the company shall clearly disclose this limitation within the same advertisement material. This includes, but is not limited to, coverage limitations, technical constraints, or service availability in specific areas.

i. Transparent Pricing and Conditions
• Where the advertisement highlights the price of an individual component within a package (e.g., a specific bandwidth number of devices), SpeedyLink shall also include: • The minimum total price required to obtain the entire service package.
• Any conditions, restrictions, or eligibility requirements that must be met to enjoy the component at the stated price. For example, fair usage policies, minimum subscription durations, or bundling prerequisites.

ii. Honest and Non-Misleading Promotions
• SpeedyLink shall ensure that all promotional materials — digital, print, or broadcast — are accurate, clear, and not misleading to consumers.
• The company shall refrain from exaggerating the capabilities, availability, or value of any part of a service court package.
• Any use of terms such as “unlimited,” “free,” or “included” shall be qualified with clear, specific explanations of applicable terms and conditions.

iii. Consumer Right to Clarification
• Consumers shall have the right to request further clarification on any advertised package before making a purchase or subscription.
• Our customer care team shall be obliged to provide honest, prompt, and clear answers to any inquiries regarding advertised packages.

c. Internet connections
• SpeedyLink shall clearly state the internet connection speed being offered to consumers in all relevant product descriptions and advertising materials.
• Where applicable, both upload and download speeds will be explicitly stated, with the typical achievable speeds for each plan clearly distinguished.
• All internet speed information will be presented in a way that avoids misleading impressions, using consistent and realistic metrics (e.g., Mbps), and will be updated if there are any changes in service performance or coverage areas.

d. Disclaimers SpeedyLink shall ensure that any disclaimers used in advertisements are:
• Understandable and do not contradict or undermine the main message of the advertisement.
• Written in clear, simple, and plain language, taking into account the medium or format (e.g., online banners, print media, radio, or TV) used.
• Properly formatted for visibility, especially on digital platforms (e.g., not hidden in small fonts or buried in footnotes).
• All disclaimers will clearly indicate the audience or segment of consumers to whom the advertisement applies (e.g., new customers, residents of specific locations, business users).

e. Telemarketing
SpeedyLink Communications ensures all telemarketing activities are transparent, respectful, and compliant with regulatory standards.
• Clear Service Information: All offers will include accurate details on connection speeds (upload/download), special conditions affecting speed, and total pricing, with no misrepresentation of service performance.
• Understandable Disclaimers: Disclaimers will be clear, concise, and relevant to the specific offer, without contradicting the main message. They will be delivered audibly during calls or clearly written in messages.
• Consumer Consent: SpeedyLink will only contact consumers who have given prior consent or are existing customers, with a simple opt-out option provided in every interaction.
• Professional Conduct: Telemarketers will clearly identify themselves, communicate courteously, and be equipped to provide accurate service information.

3. CONSUMER BILLING, CHARGING, COLLATION AND CREDIT PRACTICES
a. Billing Information
• Consumers shall receive billing information that is clear, accurate, and easy to understand.
• All bills shall specify the billing period, account number, payment due date, and payment methods.

b. Itemization of Charges
Each bill will include a detailed itemization of charges, such as:
• Monthly subscription or service fees
• One-time charges (e.g., installation)
• Taxes and levies (if applicable)
• Discount offer, promotions, or adjustments
• No hidden or unexplained charges will be applied to the consumer’s bill.

c. Timing for Issuance of Bills
• Bills shall be issued promptly at the start or end of each billing cycle, depending on service type.
d. Receipts and Consumer Payment Advice • Upon payment, consumers shall receive a receipt or confirmation via in App notification, email copy (where applicable).
• SpeedyLink shall also provide payment advice or account statements upon request, detailing past payments and current balances.

e. Billing Frequency
• Billing shall occur on a monthly basis unless otherwise specified in the service agreement or plan. • For flexible or usage-based plans, the billing frequency will reflect the agreed usage model and will be clearly communicated to the consumer at activation.

f. Non-Payment of Bills
• In cases of non-payment:
• SpeedyLink may issue reminders via In App notification, whatsApp or email.
• A grace period (as specified in the service agreement) may be provided before any service suspension or termination.
• Late payment may attract disconnection of internet service.
• Consumers are advised to settle outstanding bills promptly to avoid disruption or retrieval of equipment.

g. Prepaid Services
• For prepaid plans:
• Consumers must pay for their preferred bandwidths in advance to access services.
• Value will be automatically deducted based on a 30 days payment cycle.
• No billing statement is required; however, SpeedyLink shall provide real-time balance updates and transaction history upon request.

4. CONSUMER OBLIGATIONS
1. A consumer shall be bound by SpeedyLink Communications’ terms of service on return of a signed service agreement or having accepted the service terms by any other means of communication.
2. Pursuant to subparagraph (1) of this paragraph, the consumer shall be deemed to have accepted SpeedyLink Communications’ service terms upon commencement of the use of the service after communication by the company of its service terms.

• Access for Maintenance
A consumer shall grant the SpeedyLink Communications or its authorized staff or representatives, without charge, access to premises, equipment or facilities as reasonably required for provision, maintenance of the services, equipment or facilities.
• Misuse of Public Communication Service or Tampering with Equipment

1. A consumer shall-
(a) not use any equipment or related facility provided by SpeedyLink Communications for reasons other than those related to normal internet service, and shall not do anything that interferes with the functioning of such equipment or facility, without prior written authorization from SpeedyLink Communications; and;
(b) be responsible for any loss of or damage to equipment or facilities that result from actions contrary to service terms or this Individual Consumer Code of Conduct.

2. A consumer shall not misuse public communications services in any way, including-

(a) dishonestly obtaining communications services;

(b) possessing or supplying equipment that may be used to obtain such services dishonestly or fraudulently; or (c) using services to send messages that are obscene, threatening or otherwise contrary to applicable laws or regulations.

3. Equipment owned by SpeedyLink Communications and connected to a communications network may not be moved to a location or address other than the location or address where the service was installed, without prior written authorization of SpeedyLink Communications, but this shall not apply to any equipment that is accompanied by operating instructions indicating that it may be disconnected and reconnected as part of its normal use.

4. Modification or attachment of any unauthorized device to the SpeedyLink Communications’ equipment or facilities is prohibited without prior written authorization of the company.

5. An equipment or device that interferes in any way with the operation of a SpeedyLink Communications’ service, including any equipment or device that intercepts or assists in intercepting or receiving any service offered by the company that requires special authorization, shall not be installed by or on behalf of any consumer.

• Reselling Internet Service without Authorization:
A consumer shall not re-sell any service provided by the company except as permitted by the service agreement of the company and subject to any applicable licensing or authorization by the Commission pursuant to the Act.

5. PROTECTION OF CONSUMER INFORMATION
SpeedyLink Communications ensures that all consumer data is handled in accordance with the Nigerian Communications Commission (NCC) General Code, the Data Protection Law, and related NCC guidelines. The Company may collect and maintain information on individual consumers reasonably required for its business purposes, and the collection and maintenance of information on individual consumers shall be;

(a) fairly and lawfully collected and processed ;
(b) processed for limited and identified purposes ;
(c) relevant ; (d) accurate ;
(e) kept not longer than necessary ;
(f) processed in accordance with the consumer’s other rights ;
(g) protected against improper or accidental disclosure; and

(A) not transferred to any party except as permitted by any terms and conditions agreed with the consumer, or any permission or approval of the Commission, or as otherwise permitted or required by other applicable laws or regulations.

1. Data Gathering
• Consumer information shall only be co
llected fairly, lawfully, and for clearly defined business purposes (e.g., service activation, billing, customer support). • SpeedyLink will provide notice of:
• What data is being collected.
• Why it is being collected.
• The choices consumers have about its collection and use. Information gathering applies to verbal and written data retained in any form.

2. Data Storage
• Data shall be:
• Accurate, relevant, and retained only as long as necessary.
• Protected from unauthorized or accidental disclosure.
• Stored using industry-standard security measures to ensure confidentiality and integrity.
Consumers shall be informed of the terms and durationof data processing and have the right to access and correct their data.

3. Data Sharing
• SpeedyLink communications shall not share consumer’s data with third parties without:
• The consumer’s prior consent, or
• Legal/regulatory obligation, or
• Authorization by the NCC.
• Any shared data must be handled under a similar standard of protection by the receiving party.
• Personally identifiable data shall not be used for market analytics or revenue generation without full disclosure and consent.

Data Quality and Correction
• SpeedyLink will take reasonable steps to ensure that stored data is:
• Accurate, up-to-date, and fit for its intended purpose.
• Open to correction upon request.
• Collected fromreliable sourcesand protected from unauthorized alterations.

6. COMPLAINTS HANDLING

a. Information to Customers
SpeedyLink shall provide a Customer Care unit and appropriate facilities for handling complaints.Clear, accessible information about its complaint procedures via:

• Email Address
• Website and support links on captive Portal
• Social media platforms

A formal Complaint Handling Policy that is:
• Transparent, effective, and accessible
• Linked to Alternative Dispute Resolution (ADR) options

Guidance to consumers on:
• Their right to complain
• How to contact SpeedyLink
• Documents or details needed to lodge complaints

b. Special Needs
SpeedyLink will offer reasonable assistance to consumers who request help in submitting complaints. The company shall ensure accessible processes for:
• The elderly
• Persons with disabilities
• Other consumers with special needs
• Permit representation by authorized persons, maintaining customer confidentiality.

c. Complaint Processes
SpeedyLink Communications’ complaint process will not deter or obstruct consumers from:

(1) The Company shall ensure that the means by which they accept and process complaints do not unduly deter consumers from making a complaint. (2) The process for complaints shall include —

(a) a physical address, where the consumer can attend in person to register or lodge a complaint;

(b) a number that a consumer can call the customer care phone number;

(c) an email address ;

(d) web link on a Company’s website through which the process may equally be accessed by a consumer;

(e) social media platforms; or

(f) any other process as may be directed by the Commission.

• Timeframe for handling complaints
(1) A written complaint shall be acknowledged by a Company and acted upon within the timeframe set out in the Quality of Service Regulations issued by the Commission or as may be directed by the Commission from time to time.

(2) The Company shall acknowledge and respond to a complaint either verbally or in writing, and shall make reasonable efforts to make the initial response in the manner requested by the complainant.

(3) Where possible, a complaint shall be advised of the expected actions and timing for investigating and resolving the complaints.

(4) Where the Company regards the complaint as frivolous or vexatious, the consumer shall be informed accordingly and where dissatisfied, the consumer shall have recourse to the escalation process described in subparagraph (7) of this paragraph, provided that, no consumer complaint shall remain unresolved for more than 90 days

(5) The Company shall implement processes to provide consumers with sufficient information and the means to inquire on the progress of complaints, including complaint reference numbers or other identifiers in order to facilitate timely and accurate responses to subsequent enquiries by consumers.

(6) Consumers shall be informed of the outcome of the investigation of their complaint, and any resulting decision by the Company.

(7) Where a consumer is not satisfied with a decision reached pursuant to a complaint, the Company shall give the consumer the option of pursuing an identified escalation process by which the decision may be examined by a suitably qualified person in the Company’s organization.

(8) Where the consumer has already been provided with the benefit of the Company’s escalation process and where there are no further escalation processes, the Company shall inform the consumer.

(9) Failure to deal with consumer complaints, and any related service failures, including payment of any specific service credits or rebates shall be treated in accordance with the provisions of the Quality of Service Regulations issued by the Commission.

d. Charges
No charge will apply for standard complaint handling. Only reasonable fees may apply only when:
• Retrieving records older than two years
• Retrieval causes extra cost or inconvenience/logistics

All such charges must be:
• Disclosed to the consumer
• Agreed upon before incurring

e. Further Recourse
(1) A complaint on any service, with provision for a resolution period of —

(a) seven days or more shall be escalated to the Commission after the resolution period and shall be completely resolved within 30 days from the day the complaint was first reported to –SpeedyLink Communications; or (5) less than seven days shall be resolved in accordance with the terms of the Service Level Agreement registered with the Commission.

(2) Any other dispute referred to the Commission shall be resolved using the processes set out in its Dispute Resolution Guidelines or any dispute resolution procedure which the Commission may deem appropriate in the circumstance.

f. Action on disputed charges
(1) SpeedyLink Communications shall —

(a) not impose any disconnection or credit management action regarding any service to which a complaint or billing dispute relates while the complaint or dispute is being investigated; and

(b) inform the consumer that, while the complaint or dispute is being investigated, the consumer is obliged to make payment of any outstanding amounts other than the amount that is specifically in dispute.

(2) Where the Company intends to take disconnection or credit management action against a consumer regarding any amount that has been the subject of a complaint or dispute, the Company shall specifically notify the consumer before taking the intended action.

• Internal data collection and analysis

(1) The Company shall have appropriate recording systems for complaints and their outcomes.

(2) The record of complaints referred to in subparagraph (1) of this paragraph shall be categorized and analyzed by the Company from time to time to allow for the identification of recurring problems.

(3) The Company shall inform the consumers that records of complaints are being kept, and when requested by a consumer, the Company shall describe the complaint tracking system used.

Review of complaint handling and tracking processes
The Company shall —
(a) review its complaint handling and tracking processes from time to time to ensure effective processing of complaints;
(4) report on the outcome of these reviews as may be requested by the Commission ; and
(c) make any changes to complaint handling and tracking processes identified by the Commission.

g. Data Collection and Analysis of Complaints and Outcomes
• SpeedyLink Communications shall:
• Use a recording system to log and track complaints
• Categorize and analyze complaints to detect recurring issues
• Inform consumers that complaint records are maintained
• Describe its complaint tracking system upon request
• Conduct internal reviews of the complaint process
• Report findings to the NCC upon request
• Implement NCC-directed changes based on review outcomes

h. Changes to Complaint Handling Processes
SpeedyLink Communications shall:
• Update and communicate changes to complaint handling procedures
• Inform both consumers and the Commission of significant updates
• Reflect updates in consumer-facing documents, digital platforms, and internal systems

f. Retention of records
Information collected and recorded as part of the Company’s complaint handling processes shall be retained by the Company for a minimum period of two years following resolution of a complaint.
Complaint records and related information shall be:
• Retained for a minimum of two years after the resolution
• Made available for audit by the NCC.