Coollink Code of Practice On Confidentiality of Customer Information

This Code of Practice on Confidentiality of Customer Information is published in compliance with Section 146 of the Nigerian Communications Act, 2003, for the fair handling of personal information. The provisions of this Code are in addition to and not in reduction of the obligation of Coollink under the said Act.

It is Coollink's policy not to disclose customers' information to anyone except the customers, or in accordance with any instructions or permission the customers have given to Coollink. However, there are circumstances in which Coollink may be required by law to disclose information. Such requests normally come from statutory authorities e.g. Police Forces, Customs and Excise etc. Any such disclosure will be strictly controlled and fully in accordance with current legislation of the Federal Republic of Nigeria.

Who we are
Coollink is an Internet Service Provider inspired by STEAM Broadcasting & Communications Limited and registered by the Nigerian Communications Commission (NCC) to provide a broad range of Internet services to both commercial and domestic (consumer) clients. Services to consumers include dial-up and broadband Internet access, web space hosting and email together with other accessory services. Consumer services are delivered to individual clients and small businesses.

Confidentiality of information
Coollink and Coollink Authorized Resellers hold customers' personal information in strict confidence. All employees and Resellers observe a code of practice that regulates the disclosure of information about customers that they might gain as part of doing normal business with you.

Coollink will:

• Keep confidential the business records, personal details and information of or relating to each user and will respect the privacy of users' personal communications;
• Take adequate steps to ensure the confidentiality of business records, personal details and information
• Not sell or exchange the business records, personal details or information of a user other than to another company as part of the sale of the Coollink's business as a going concern
• Refrain from intentionally examining or tampering with a user's business records, personal details or information without the express prior consent of the user except to the extent required by a properly qualified officer for the maintenance of system security or data integrity
• Treat email as private content whether in transit or in storage.

The above clause does not prevent disclosure of information with the express or implied consent of the user or as required by law. Nothing in this Code in any way releases Coollink from more onerous secrecy obligations imposed by statute or contract or equity, or other industry code of practice to which they may be bound. Nothing in this Code prevents Coollink from collecting anonymous aggregate information regarding its users or the use of its service.

Collection and use of user details
Coollink will collect details relating to a user only if relevant and necessary for the provision of the service or product that the Coollink is engaged to provide, or for other legitimate purposes made known to the user prior to the time the details are collected.

Coollink will use details relating to a user only for:

• Coollink's internal marketing, billing or other purposes necessary for the provision of the service
• Purposes made known to the user prior to the time the details are collected
• Other purposes with the prior consent of the user.

Coollink will take reasonable steps, having regard to the nature of the information, to ensure that information collected in relation to a user:

• To the extent that it comprises business records or details in relation to a particular individual, can be checked by a user.
• Is accurate, and if necessary, kept up to date.
• If inaccurate, is erased or rectified
• Is erased at the request of the user and/or when no longer reasonably required.

In this part of the Code, references to the collection of details include collection of details by active request or inquiry and collection of details by passive recording of actions or activity.