This Privacy Statement and Cookies Policy (the "Privacy Policy") is located on the website, www.ibedc.com (the "Website"). The Website is operated by Ibadan Electricity Distribution Company PLC (registered number 638633), a Public liability company, incorporated in Nigeria whose registered office is at Capital Building, 115 MKO Abiola Way (Ring Road)Ibadan, Oyo State and all of its direct and indirect subsidiaries ("we" or "our" or "the Company" or “IBEDC”).

This Privacy Policy (together with our Terms of Use and any other documents referred to in such Terms of Use) sets out the basis on which any personal data we collect from you, or that you otherwise provide to us, will be processed and used by us and applies to all of your personal data irrespective of the medium or method by which we obtained/received your personal data.

Please read the following carefully. Entering into the Website and/or by providing us with your personal data by other means indicates that the user (either "user" or "you") has either reviewed this Privacy Policy or been given an opportunity to review this Privacy Policy and has agreed to be bound by it as well as our Terms and Conditions. If you do not agree to these terms you must leave the Website immediately and/or send us a written request to delete any personal information on you otherwise you give us permission to use your personal data in accordance with this Privacy Policy. Please note that we may not be in a position to provide you with services if we cannot use your personal data.

Click here: IBEDC Privacy Policy

What information do we collect?

We fully respect your right to privacy in relation to your interactions with us via the Website and over the phone and in any other form of communication with the Company and endeavor to guarantee to be transparent in our dealings with you as to what information we will collect (such as your name, customer account number, MPRN, date of birth, address, phone number/secondary phone number and email address and preferences), and how we will use your information. Also, we only collect and use individual user details where we have legitimate business reasons, and where we are legally entitled to do so.

IBEDC complies with the Data Protection under the following basis: The Nigerian Constitution, the Nigerian Communication Act, and the Freedom of Information Act and under the Financial Sector.

How do we collect information from you?

• IP Addresses

We automatically collect IP addresses from visitors to our Website (an IP address is a number that can uniquely identify a specific computer or other network device on the internet) and log these IP addresses as part of the connection of your computer to the Company's web server. This allows us to identify the location of users, to block disruptive use, and to establish the number of visits from different countries. We analyze this data for trend and statistics reasons, such as which parts of our Website users are visiting, how many times and how long they spend there.

• Cookies

We collate information on all our Website traffic that is represented in aggregate format through cookies. A cookie is a small text file that is placed on your hard disk by web page server which enables a website to recognize repeat users, facilitate the user's ongoing access to and use of the Website, and allows the Website to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising. A cookie will not provide us with personal information, therefore if you have not supplied us with any personal information you can still browse the Website anonymously. We use third parties such as i.e. Google Analytics to collect user information, including through the use of cookies (flash and non-flash) and web beacons. They help us to improve our Website and to deliver many of the functions that make your browser experience more user friendly. You can find a list of cookies we use and the purposes for which we use them in the table below. Additional cookies will be added from time to time.

THIRD-PARTY COOKIES

There are cookies which are found in other companies' internet tools which we are using to enhance the Website. You will see ‘social buttons’ on our Website, which enable you to share or bookmark the web pages.

PROVIDER NAME PURPOSE MORE INFO

Google Analytics Performance Cookie Third Party To provide insights into our website traffic and collect information about how visitors use our website

Google Adwords Conversion

Advertising Cookie Third party to measure advertising performance of adwords campaigns

Double Click Advertising Cookie Third-party Google's DoubleClick products provide ad management and ad serving solutions to companies that buy, create or sell online advertising

Double Click Floodlight Advertising Cookie Third party to track and report on advertising conversions

Right Media Advertising Cookie Third party to provide ad management and ad serving solutions

By using the Website and/or accepting our Privacy Policy we assume that you are agreeing to the placement of cookies on your device unless you specifically choose not to receive cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer. For more information about cookies and managing them, including how to turn them off, please visit www.cookiecentral.com. However, because cookies allow you to take advantage of some of the Website's essential features, we recommend you leave them turned on as otherwise, you may not be able to fully experience the interactive features of this or other websites which you visit.

If you wish to opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

• Registration Process

To register as a customer or if you wish to enquire about our services we need to collect information via our Website or over the phone or any other form of communication such as, at a minimum, your name, email address, and a password. We may also ask some further questions so we can gain a clearer understanding of what you are interested in, in order to personalize the information we give you. (You can update your personal information held and change your stated interests. You may unsubscribe from certain updates by emailing [email protected]. We may ask different questions for different services. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

• Mobile Devices

Applications developed in connection with the Website for mobile devices will operate and capture information as set out above. Applications developed by us but deployed on other platforms such as social media channels may provide feedback to us on activity and usage specific to a user.

How do we use the information we collect?

We collect different types of information about our users for the following reasons:

1. For activities relating to the provision of prepaid electricity services. This includes activities such as meter installation, switching of your electricity supply, and monitoring top-ups and electricity usage for revenue assurance and fraud prevention purposes.

2. To personalize the way our content is presented to you (including advertisements) and to ensure that content from our Website is presented in the most effective manner for you and for your computer and to provide the services or carry out the transaction you have requested;

3. To help us to monitor and improve the services we offer, including this Website and over the phone, and to develop new services. As part of this, we may use and disclose information in aggregate (so that no individuals are identified);

4. to process, validate, and verify requests for services and for the purposes for which you specifically provided the information;

5. We may use the information to verify with third parties (such as councils or property owners) that appropriate permissions have been obtained in relation to the transfer of electricity supply and installation of a meter.

6. To carry out any legal obligations arising from your interaction with the Website and the provision of our services to you; and

7. To allow you to participate in interactive features of our service when you choose to do so.

We may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you including special offers and we or they may contact you about these. By accepting this Privacy Policy, you agree to be contacted by any such third parties. The data that we collect from you may be transferred to and stored by the Company. It may also be processed by staff of the Company. By submitting your personal data, you agree to this transfer, storing, or processing of your data by the Company.

Are there cases where we may use your information to contact you?

We may contact you:

• As your electricity supplier we may choose to contact you in relation to your account or in relation to your supply (E.g. Network upgrades planned outages or price changes relating to the NERC’s order or other standing or fixed and per unit charges.

• As your electricity supplier, we may contact you where there are periods with no vending activity or where consumption as measured (or estimated) and does not balance with your supply.

• For reasons highlighted in our Terms and Conditions and Code of Practice.

• For administration reasons related to the service to which you have signed up (e.g. to notify you that a particular service, activity, or online content has been suspended for maintenance, or in response to a question that you ask us);

• To provide you with information about our services, activities or online content;

• To provide you with selected promotions and offers;

• To invite you to participate in surveys about our services (participation is always voluntary).

Where we wish to use your personal information in any other way, 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 in this document via an easy method of unsubscribing from future messages at no cost to you.

How we protect your personal information

We do our utmost to protect user privacy through the appropriate use of the security technology: we ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures. The personally identifiable information we collect about you is stored in limited-access servers. We maintain safeguards to protect the security, integrity, and privacy of these servers and your personally identifiable information.

However, this Website contains hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk. The Company recommends that you review the privacy statement and cookies policy at each website you visit to determine how that particular website protects your privacy.

Who we share data with

We may disclose your personal information to any company or other corporate entity under the control and direction of the Company.

As stated above we may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you and we or they may contact you about these.

We reserve the right to access and disclose personal data to comply with applicable laws and lawful government requests, to operate our systems properly, and to protect both ourselves and our users. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also use service providers to help us run the Website or to assist us to provide the services we provide to our customers. Any third parties who access your data in the course of providing services on our behalf are subject to strict contractual restrictions to ensure that your data is protected, in compliance with data protection legislation.

We may disclose your personal information in the event that we sell or buy any business or assets, in which case we may disclose your personal information to our professional advisers, the prospective seller or buyer of such business or assets or their professional advisers. If the Company or substantially all of our assets are acquired by a third party, your personal information held by us will be one of the transferred assets.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside Our Network Franchise Area. It may also be processed by staff operating outside our Network Franchise Area, but who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Opt-Out

• Non-customers

You can exercise your right of opt-out to prevent such processing of your personal information by sending us such written request by prepaid post to:

Data Opt Out, Ibadan Electricity Distribution Company PLC, Capital Building, 115 MKO Abiola Way (Ring Road) Ibadan, Oyo State.

• Customers

You may not opt-out unless and until your contract with us has terminated, however you may request that your personal data not be used for marketing purposes by sending us such written request by prepaid post to:

Data Opt Out, Ibadan Electricity Distribution Company PLC, Capital Building, 115 MKO Abiola Way (Ring Road) Ibadan, Oyo State.

Retention of Personal Data

Any information that you provide will be kept and stored for such a period of time that the Company deems appropriate taking into account all of our obligations under the Data Protection Regulations.

Updating Your Information

It is your responsibility that all of the personal information provided to us is accurate and complete. If any information you have given us changes, please let us know either by writing to us at Legal Department Ibadan Electricity Distribution Company PLC, Capital Building, 115 MKO Abiola Way (Ring Road) Ibadan, Oyo State or by emailing us at [email protected] specifying your account/ MPRN on all correspondences.

Employment Application

If you use the Website to make an application for employment with us, you acknowledge: (i) that the Company will not under any circumstances be liable to you should your application be unsuccessful or should your application not be received; (ii) that the technology utilized by the Company and its third party suppliers is designed to protect personally identifiable information but that the Company is unable to guarantee that all such personally identifiable information is not capable of being illegally accessed; (iii) that accordingly you assume all risk associated therewith and agree that the Company shall not under any circumstances be liable to you in respect thereof; (iv) that you provide any information solely at your risk and; (v) that any information provided will be kept and stored for such period of time the Company deems appropriate.

Payments

The Company may collect financial information such as banking card information when a payment is made. We do not share this information with anyone outside the Company, other than other companies and individuals we employ to perform functions on our behalf such as sending mail and processing payments and this information will not be kept longer than necessary for providing the services. Any such company or individual will have access to personal information needed to perform these functions but may not use such personal information for any other purpose.

Changes to the Privacy Policy

This Privacy Policy may be updated from time to time, so you may wish to check it each time you provide personal information to us. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use this Website to submit personal information or submit personal information to us in any other way. If material changes are made to the Privacy Policy, we will notify you by placing a prominent notice on the Website. We will not use your personal information in a manner different from this Privacy Policy without your consent.

Consent

• Via the Website

By accessing services offered by us or by providing information to us via our Website, you consent to the collection and use of this information as outlined in this Privacy Policy. By providing any personal information to us, you fully understand and clearly consent to such use and transfers as set out in this Privacy Policy.

• Over the Phone

By accessing services offered by us over the phone or by providing information over the phone, you consent to the collection and use of this information by us as outlined in this Privacy Policy. By providing any personal information to us, you fully understand and clearly consent to such use and transfers as set out in this Privacy Policy.

• By Any Other Means

By accessing services offered by us by any other means, you consent to the collection and use of this information by us as outlined in this Privacy Policy. By providing any personal information to us, you fully understand and clearly consent to such use and transfers as set out in this Privacy Policy.

Legal information and how to contact us

The Data Controller for the Website and services provided by us is the Company.

You have the right under the Data Protection laws to access the information we hold about you. If you would like to obtain a copy of the personal information we hold on you, or have any queries regarding the Company's use of personal information please contact us by submitting a request to us in writing accompanied with a postal order for the applicable fee of N1000 (One thousand Naira only) to Data Access Requests, Ibadan Electricity Distribution Company PLC, Capital Building, 115 MKO Abiola Way (Ring Road) Ibadan, Oyo State.

We reserve the right to contact you at any time regarding any problems or questions as well as to notify you of changes to the Privacy Policy or to other policies or terms that affect you and your use of the Website or our services, but we are not obliged to do so.

If you have any questions about this Privacy Policy, the contents of this Website or our services, you can contact us