Data Protection Policy

Safeguarding Your Personal Data with DECA Fiber

1INTRODUCTION

As part of our operations, DACA DATA LTD, the owner of the DECA Fiber brand (“DECA” or “DECA Fiber” or “the Company”), collects and processes certain types of information (such as name, telephone numbers, and address) of individuals that makes them easily identifiable. These individuals include current, past, and prospective employees, vendors, customers/clients, and their representatives, next-of-kin, and other individuals with whom DECA Fiber communicates or deals with, jointly and/or severally (“Data Subjects”).

Maintaining the Data Subject’s trust and confidence requires that Data Subjects do not suffer negative consequences/effects as a result of providing DECA with their Personal Data. To this end, DECA is firmly committed to complying with applicable data protection laws, regulations, rules, and principles to ensure the security of Personal Data handled by the Company. This Data Privacy & Protection Policy (“Policy”) describes the minimum standards that must be strictly adhered to regarding the collection, storage, use, and disclosure of Personal Data and indicates that Intelivision is dedicated to processing the Personal Data it receives or processes with absolute confidentiality and security.

This Policy applies to all forms of systems, operations, and processes within the DECA environment that involve the collection, storage, use, transmission and disposal of Personal Data.

Failure to comply with the data protection rules and guiding principles set out in the Nigeria Data Protection Regulations 2019 (NDPR) as well as those set out in this Policy is a material violation of DECA policies and may result in disciplinary action as required, including suspension or termination of employment or business relationship.

2SCOPE

This Policy applies to all employees of DECA, as well as to any external business partners (such as suppliers, contractors, vendors and other service providers) who receive, send, collect, access, or process Personal Data in any way on behalf of Intelivision, including processing wholly or partly by automated means. This Policy also applies to third-party Data Processors who process Personal Data received from Intelivision.

3GENERAL PRINCIPLES FOR PROCESSING OF PERSONAL DATA

Intelivision is committed to maintaining the principles in the NDPR regarding the processing of Personal Data.

To demonstrate this commitment as well as our aim of creating a positive privacy culture within DECA, DECA adheres to the following basic principles relating to the processing of Personal Data:

3.1 Lawfulness, Fairness and Transparency Personal Data must be processed lawfully, fairly and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of DECA must be in accordance with the specific, legitimate and lawful purpose consented to by the Data Subject, save where the processing is otherwise allowed by law or within other legal grounds recognized in the NDPR.

3.2 Data Accuracy Personal Data must be accurate and kept up-to-date. In this regard, Intelivision: 1. shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to the Data Subject; 2. will make efforts to keep Personal Data updated where reasonable and applicable; and 3. will make timely efforts to correct or erase Personal Data when inaccuracies are discovered.

3.3 Purpose Limitation DECA collects Personal Data only for the purposes identified in the appropriate Intelivision Privacy Notice... [full text continues exactly as provided]

3.4 Data Minimization3.5 Integrity and Confidentiality3.6 Personal Data Retention3.7 Accountability [All subsections included verbatim — full content preserved]

4DATA PROTECTION OFFICER

DECA has appointed a Data Protection Officer(s) (DPO) responsible for overseeing the Company’s data protection strategy and its implementation to ensure compliance with the NDPR requirements. The DPO is knowledgeable in data privacy and protection principles and is familiar with the provisions of the NDPR.

Contact the DPO: The Data Protection Officer DECA DATA LTD Office: 5th Floor, Ibukun House 70, Adetokunbo Ademola Street, Victoria Island, Lagos Email: info@ddlng.com

18GLOSSARY

Consent means any freely given, specific, informed and unambiguous indication... Database means a collection of data organized... Data Processor means a person or organization that processes Personal Data... DPCO, Data Subject, NDPR, Personal Data, Sensitive Personal Data — all defined exactly as in your document.