Code of Conduct

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NCC CODE OF CONDUCT


1. INTRODUCTION

VDL Technologies is a Value-Added Services (VAS) provider licensed by the Nigerian Communications Commission (NCC) to offer value added services to the telecommunications industry. We enable our subscribers (through the mobile operators) to access a wide range of additional services such as Caller Ring Back Tunes (CRBT), SMS Infotainment and Entertainment Content, as well as a host of services over IVR. Access to these services can either be via SMS, IVR or WEB.

i. Purpose of the Code Nigerian Communications Commission (NCC) has advised all licensed telecommunications service providers in Nigeria to provide a Consumer Code of Practice.

This Code of Practice:

      a. Describes the main services we provide to our customers;
      b. Explains how to contact us about these services and how you can subscribe to our services;
      c. Explains the customer’s rights and obligations; and
      d. Describes what to do if you have a complaint, how we will resolve it, and what you can do if you are not satisfied with our response.

ii. Application of the Code - This Code applies to the provision of Value Added Services to the telecommunications industry based on VAS license obtained by VDL from the NCC. It has been developed by VDL in line with the established and published NCC’s General Code of Practice.

iii. Code Administration- The Code will be administered by VDL in line with guidelines from NCC as well as reviews that are to be agreed and communicated by the Commission based on feedbacks at Consumer Forums that may be set-up by NCC from time to time.

iv. Code Amendment- VDL may amend this Consumer Code from time to time to conform to set guidelines that may be required by Law or by the NCC.


2. PROVISION OF INFORMATION TO CONSUMERS

i. General Separate minimum periods will apply to the service we supply to you and to other users depending on the pricing option and service you choose. The minimum service duration or period of service for some of our services is a daily request while the maximum period of service for our services is 5days (renewable on expiry). For our SMS services, the service will begin on the day you purchase the service via SMS as activation is done almost immediately. Please note that VDL’s services are available in all parts of Nigeria. However, our services are network dependent and certain services may not be available on all networks.

ii. Contracts & Duration Prior to requesting the service- Every subscriber will be expected to read our terms and conditions which details full terms under which we provide products and services to our customers. It governs the contractual relationship between us and if any discrepancy exists between the Service Contract and Consumer Code of Practice, the Service Contract shall take precedence.

iii. Description of Services- We have a lot of services ranging from Caller Ring Back Tunes, WAP, USSD SMS Content such as Education, Sports, Entertainment, Health, Videos services and a host of other services as our service catalogue expands almost daily. For detailed description and pricing of our services, please send an email to info@vdltechnologies.com.

iv. Terms & Information- A sample of our contract terms and related information can be made available upon request.

v. Opt in and Opt Out of Services- VDL shall inform consumers of their right to opt in or opt out of any advertised or subscribed service. To ensure that this is achieved, VDL shall have readily accessible mechanisms/paths to subscribe (‘opt in’) to service.

      a. To subscribe to any of our services, the subscriber sends the key word for that service to the designated short code.
      b. In response the subscriber gets a confirmation message confirming that he/she has been subscribed for that service.
      c. To opt out of a service the subscriber sends “STOP + KEYWORD” to the designated short code for that service. For instance you send STOP JEN to 8010 to opt out of Jenifa’s Diary service.
      d. In response the subscriber gets a confirmation message stating that the subscriber has been unsubscribed from that service.

vi. STEPS TAKEN BY VDL TO PROVIDE SERVICE IN A TRANSPARENT MANNER

      a. VDL ensures to monitor all subscriber queries and complaints received in relation to content and services rendered by VDL.
      b. VDL has a management structure put in place to ensure the service keywords are working always to ensure easy opt-in and opt-out.
      c. VDL ensures its service users get charge notifications when necessary.
      d. VDL ensures DND and DNC lists are updated as soon as the request comes in.
      e. We have a standby customer care team to ensure easy and prompt redress or resolution of Service Users’ complaints.
      f. VDL ensures customers with complaints are refunded in airtime when necessary.
      g. We ensure that marketing message(s) are not delivered to subscribers on the ‘Do Not Disturb’ database.
      h. VDL ensures to implement deactivation i.e. prevent subsequent charging, directives once any deactivation request comes in.
      i. VDL has a structure to ensure Broadcast of marketing messages (IVR, USSD, SMS) are always done between 8am – 8pm in compliance with NCC regulations and directives.
      j. VDL ensures we do not go ahead with the launching of a content service without official approval from the network operators.
      k. VDL ensures there is no delivery of inappropriate content (including but not limited to messages of a sexual, religion-intolerant, culture or race-intolerant or politically insidious nature).
      l. We ensure we do not deliver repeated or inaccurate content to customers subscribed to a service.
      m. We ensure to deliver VAS subscribed to and paid for by customers on the service.

3. ADVERTISING AND REPRESENTATION OF SERVICES

i. Advertising Practitioners Council of Nigeria (APCON) All marketing materials shall be prepared in line with the standard adverting codes from APCON as well as the Consumer Affairs departments of NCC.

ii. Availability of Service VDL communication services are not available on all mobile networks and as our services are network dependent, services will be restricted to certain areas within Nigeria where mobile network service is available.


4. CONSUMER BILLING

I. All services are paid for via credit available on the subscribers’ phone. Once service is requested for, the money is deducted from the balance of the customer’s account.

II. Unless otherwise promoted or advertised, we will normally bill you upfront (in advance) for any charges for the duration of the service.


5. CONSUMER OBLIGATIONS

i. Acceptance of Licensee Terms Consumers shall be bound by VDL’s terms of service once service is requested for. By activating the service on commencement date, you are deemed to have accepted our service terms.

ii. Non Misuse of Service Consumers shall not misuse our services, including but not limited to: dishonestly obtaining services; or using services to send messages that are obscene, threatening or otherwise contrary to applicable laws or regulation.


6. PROTECTION OF CONSUMER INFORMATION

We know that privacy is very important to our customers and we want you to feel confident about the privacy and security of your personal information. We take reasonable care to prevent any unauthorized access to your personal information. VDL recognizes the importance of your privacy. We use personal information that we collect from customers in accordance with strict procedures and laws of the Federal Republic of Nigeria. We have set out below some important information about the personal information we may hold about you, and how we use it. Full details of our Privacy Policy can be made available by writing to us at: VDL Technologies, Block B, Suite 16, 1st floor LSPC Mall, 129/131, Obafemi Awolowo Way, Ikeja Lagos.

i. General Principles When ordering for certain services, we may ask you for information such as name, address, contact phone numbers and email address. We may also ask you other relevant information about the service you are using or ordering.

ii. How we Use your Personal Information We use information about you in the following way: • Process of orders you place with us • Charge for services we provide

  • Publish your details in our highly secure directory, provide directory enquiry service or information to the regulator, NCC and other authorized government agencies
  • Communicate with you about how to use the service and let you know about any changes to the service
  • Market our own products and services. We need your permission to use your information for this purpose. We will assume we have your permission unless you tell us otherwise by writing to us at: VDL Technologies, Block B, Suite 16, 1st floor LSPC Mall, 129/131, Obafemi Awolowo Way, Ikeja Lagos.
  • Carry our market research and analysis on our current products and services and future developments. We will make sure that you cannot be identified. We may give information in this form to certain other people or organizations.
  • Prevent and detect criminal activity, fraud, misuse of or damage to our network and prosecute and sue those responsible.
  • We may provide information (in response to requests from authorized law enforcement agencies) to prevent and detect crime and prosecute offenders. We may also provide information to protect national security. In all cases, we will do so in line with the laws of Federal Republic of Nigeria.

iii. How long we keep personal information - How long we keep personal information depends on how we use that information. In some cases, by law we must keep information for a minimum period. Unless specific legal requirements say otherwise, we will keep information no longer than is necessary for the purpose we collected or processed the information.

iv. Change to our Privacy Policy - We may make changes to our Privacy Policy from time to time. Your continuing use of any of our services indicates your agreement to the use of your personal information as set out in this Privacy Policy.

v. Maintaining Data Quality - We take due care in ensuring that personal information provided by you are retained and processed in a manner that ensures that this information is accurate, relevant and current for the purpose for which it is to be used for.


7. COMPLAINTS HANDLING

i. Information to Consumers - If you are unhappy with our service please contact us and let us know. It is through your feedback that we are able to review and improve the overall service we provide. If you have a complaint our formal internal complaints procedure is outlined below. We are fully committed to addressing all complaints, fully and fairly, and in a reasonable time frame. We do try and resolve complaints by telephone, however, should you wish to receive a response in writing then please let us know and we will duly send you a written resolution to your complaint.

ii. Fault Process VDL operates a customer service desk which is reachable during working hours (9:00am – 5:00pm) via telephone and outside working hours via e-mail. All VDL Technologies subscribers can contact the help desk via telephone: +2348187337861 | email: info@vdltechnologies.com. Before you contact our support desk please make sure that you have the service you are subscribed to, your mobile number, your username (if any) and summary of the complaint. This will enable us process and resolve your complaints quickly.

iii. Resolution Time - We aim to deal with problems as quickly as possible and so our help desk assistance will try to resolve the problem as soon as possible. If this is not possible, they will inform you of a cause of action.

iv. Escalation - If you need to escalate a complaint about the way we have handled any aspect of your account or the way you have been treated when contacting the technical support or Customer Service desks you may escalate by writing detailing the nature of the complaint to: Chief Operating Officer - VDL Technologies,Block B, Suite 16, 1st floor LSPC Mall, 129/131, Obafemi Awolowo Way, Ikeja Lagos.

v. Contacting - You When we need to contact you, we will use your e-mail address, mobile or fixed phone number. We will contact you to advice on the outcome of an investigation to any complaint which our help desk agents were unable to resolve during the initial telephone call.

vi. Special Needs - VDL is aware of its legal and moral obligations to disabled customers. We offer a number of different services for our customers with special needs. These services are designed to not only meet the demands of the current regulations, but to also enable us to offer the best possible service to these customers.

vii. Special Literature Copies of this code of practice in larger print are available by post from us. Our web developers are also working continually to improve the accessibility of our sites to disabled customers.

viii. Charges Complaint handling processes shall be provided free of charge. However, we may impose a reasonable charge for complaint handling processes where investigation of the complaint requires the retrieval of records more than twelve (12) months old, and where that retrieval results in any incremental expense or significant inconvenience. Any such charges shall be identified, communicated and agreed with the subscriber before we bill for it.

ix. Action on disputed charges - When there is an unresolved complaint or billing dispute, the consumer shall be obliged to make payment of any outstanding amounts other than the amount that is specifically in dispute. We shall not impose any additional charges in form of credit management or interest while the dispute is being resolved.

system used by us. We have appropriate recording systems for complaints and their outcomes. Such complaints tracking data shall be categorized and analyzed from time to time to allow for the identification of recurring problems.

x. Data Collection and Analysis of Complaints and Outcome - A record of your complaints is being kept and if requested, we shall describe the complaints, tracking

xi. Changes to complaint Handling Process - We shall from time to time and as may be required by NCC review our complaint handling process. Revised and updated information will be posted to our website: www.vdltechnologies.com

xii. Retention of Records - Information collected and recorded as part of our complaint handling processes shall be retained by us for at least twelve (12) months following resolution of a complaint.


8. CODE COMPLIANCE

i. Licensees (VDL’s) Responsibility - VDL takes its responsibility to the code compliance very seriously and recognizes the importance of developing and maintaining a good Code that is approved by the commission. The company is committed to an ongoing process of improvement in its operational performance, seeking not only to comply with legal or mandatory requirements but also proactively educate her employees regarding the code compliance and providing the required information to the Commission as at when needed.

ii. Compliance Monitoring and Reporting by the Commission VDL is in full support and agrees to work with the Commission as well as customers to ensure that the service it delivers in terms of quality and customer support continues to meet and even exceed developed standards and codes of conduct.

iii. Consumer Complaints - All complaints by consumers will first be lodged and dealt with VDL in accordance with Clause 7 of this Code. Where a Consumer lodges a complaint with the Commission and does not initially contact us, the Commission will forward the complaint to VDL for resolution in accordance with our complaint handling process detailed in this Code.

iv. Industry Complaints Industry complaints are those made by one Licensee against another for an alleged breach of a consumer code. Industry complaints will also include complaints by a group representing consumer interests against a Licensee.

v. Commission Investigation - The Nigerian Communications Commission (NCC) is empowered by law and is fully responsible for ensuring compliance as well as investigation into complaints or breach of code by either VDL, her customers or between VDL and other providers.

vi. Appeals Process - Where there is a dispute between us that cannot be resolved within 60 days from the first date of lodging the complaint with us, you have the right to refer the matter to the Head, Consumer Affairs department of the Nigerian Communications Commission.

vii. Confidentiality - We will treat any information concerning any complaint or compliance in confidence and will not disclose it to anyone except or in accordance with any instructions you have given us. However, there are circumstances in which we may be required by law to disclose information. Such requests normally come from Statutory Authorities, for example, Police Forces, EFCC and Excise etc. Any such disclosure will be strictly controlled and will be made fully in accordance with the laws of the Federal Republic of Nigeria.