Privacy Policy

Termii cares about your privacy. For this reason, we collect and use personal data only as it might be needed for us to deliver to you our world-class products, services, and websites (collectively, our “Services”). Your personal data includes information such as:

• Name
• Address
• Telephone number
• Email address
• Other data collected that could directly or indirectly identify you.

Our Privacy Policy is intended to describe to you how and what data we collect, and how and why we use your personal data. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process.

If at any time you have questions about our practices or any of your rights described below, you may reach our dedicated team that is responsible for this by contacting dataprotection@termii.com. This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.

What information do we collect?

We collect information so that we can provide the best possible experience when you utilize our Services. Much of what you likely consider personal data is collected directly from you when you:

• Create an account or purchase any of our Services (e.g. billing information, including name, address, and credit card number);
• Request assistance from our customer support team (e.g. phone number);
• Complete contact forms or request newsletters or other information from us (e.g. email); or
• Participate in activities we promote that might require information about you.

However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance. These methods of collection may not be as obvious to you, so we wanted to highlight and explain below a bit more about what these might be (as they vary from time to time) and how they work:

Account-related information is collected in association with your use of our Services, such as account number, purchases, when products renew or expire, information requests, and customer service requests and notes or details explaining what you asked for and how we responded.

When you use our AI Services (including AYLA), we may collect:

• Customer Inputs – prompts, instructions, messages, documents, telephone numbers, and any other data you submit to the AI Services.
• AI Outputs – generated recommendations, summaries, translations, routing decisions, fraud alerts, and other outputs produced by the AI models.
• Operational telemetry – metadata about your interactions with AI features (e.g. which features you use, frequency, error logs) to improve performance and security.

Cookies and similar technologies on our websites and our mobile applications allow us to track your browsing behavior, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our Services. This allows us to provide you with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyze and improve the performance of our Services. We may also collect your location (IP address) so that we can personalize our Services.

Data about usage of Services is automatically collected when you use and interact with our Services, including metadata, log files, cookie/device IDs, and location information. This information includes specific data about your interactions with the features, content, and links contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, and some of this data collected might be capable of and be used to approximate your location.

Website analytics. We use multiple web analytics tools provided by service partners such as Google Analytics, MixPanel, and Hotjar to collect information about how you interact with our website or mobile applications, including what pages you visit, what site you visited before visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our Services.

Third-party websites. Our website and our mobile applications contain links to third-party websites. We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit.

Supplemented data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyze the accuracy of our records, identify new customers, and provide products and services that may be of interest to you.

How we utilize information

We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that for which we have been given permission, as necessary to deliver the Services you purchase or interact with, or as we might be required or permitted for legal compliance or other lawful purposes. These uses include:

Delivering, improving, updating, and enhancing the Services we provide to you. We collect various information relating to your purchase, use, and/or interactions with our Services. We utilize this information to:

• Improve and optimize the operation and performance of our Services
• Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
• Detect and prevent fraud and abuse of our Services and systems
• Collect aggregate statistics about the use of the Services
• Understand and analyze how you use our Services and what products and services are most relevant to you
• Provide AI-Assisted Features – process Customer Inputs to generate AI Outputs for communication workflows, routing, fraud detection, summarisation, and other functions
• Improve AI Models – we may use aggregated and de-identified operational data, service metrics, telemetry, and diagnostic information to enhance the security, performance, reliability, and effectiveness of the AI Services. This use does not identify you or any individual
• Training Data Restrictions – we do not use Customer Inputs to train publicly available foundation models unless we have a separate written agreement with you. Any model improvement using your data beyond the purposes stated will be subject to explicit consent or a separate contract
• Compliance and Safety – we may process data to detect and prevent fraud, abuse, unlawful activity, or security threats related to the AI Services, as permitted by applicable law

Sharing with trusted third parties. We may share your personal data with affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our Services, and with trusted third-party service providers as necessary for them to perform services on our behalf, such as:

• Processing credit card payments
• Serving advertisements (where we have obtained consent from you, where applicable)
• Conducting contests or surveys
• Performing analysis of our Services and customers’ demographics
• Communicating with you, such as by way email or survey delivery
• Customer relationship management
• AI Service Providers

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing, or retaining your personal data for any other purpose than as they have been specifically contracted for (or without your consent).

Your rights

You have certain rights in relation to the way we handle your Personal Data. These include the following rights:

• where the legal basis of our processing is consent, to withdraw that consent at any time;
• to ask for access to the Personal Data that we hold;
• to prevent our use of the Personal Data for direct marketing purposes;
• to object to our processing of Personal Data in limited circumstances;
• to ask us to erase Personal Data without delay: if it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; if the only legal basis of processing is consent and that consent has been withdrawn; or if the processing is unlawful;
• to ask us to rectify inaccurate data or to complete incomplete data;
• to restrict processing in specific circumstances e.g. where there is a complaint about accuracy;
• the right not to be subject to decisions based solely on automated processing, including profiling, except where necessary for a contract, based on explicit consent, or authorised by law;
• to prevent processing that is likely to cause you damage or distress to anyone else;
• to data portability;
• to be notified of a Personal Data Breach which is likely to result in high risk to your rights and freedoms;
• to make a complaint to the appropriate data protection regulatory body;
• in limited circumstances, receive or ask for your Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

Right to Object to Automated Decision-Making: you have the right not to be subject to decisions based solely on automated processing, including profiling, where they produce legal or similarly significant effects. Termii’s AI Services are advisory and do not make autonomous decisions that replace human judgment. However, if you believe AI Outputs are being used in such a way, you may contact us to request human review.

Right to Information About AI Processing: you may request an explanation of the logic involved in AI-based processing, the significance, and the envisaged consequences for you.

Transfer of personal data abroad

If you utilize our Services, your communications with us may result in transferring your personal data from Nigeria across international borders. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws. If the receiving country does not have an adequacy decision or equivalent data protection standards, we will implement legally recognised measures to ensure the security and confidentiality of your personal data.

In any case, where your personal data is transferred to another country, it will be handled according to this Privacy Policy.

Compliance with legal, regulatory and law enforcement requests

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you if we are required to provide your personal information to third parties as part of the legal process.

How you can access, update or delete your data

To easily access, view, update, delete or port your personal data (where available), or to update your subscription preferences, please sign in to your Account and visit “Account Settings.”

If you request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

If you are unable for any reason to access your Account Settings, you may also contact us by one of the methods described in the “Contact us” section below.

How we secure, store and retain your data

We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.

We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes.

AI data retention: Customer Inputs and AI Outputs are retained only as long as necessary to provide the requested AI Services and for legitimate business purposes (e.g. audit, dispute resolution, legal compliance). We may retain de-identified operational data for model improvement indefinitely, provided it does not identify you. If you delete your account, we will remove your personal data in accordance with our deletion policy, except where we are legally required to retain it.

Age restrictions

Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by, or designed to entice individuals under the age of 18. By using our Services, you warrant that you are not under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.

Contact us

If you have any questions, concerns, or complaints about our Privacy Policy, our practices, or our Services, you may contact our office by email at dataprotection@termii.com. In the alternative, you may contact us by either of the following means:

• By Mail: Attn: Legal Officer, 1 Towobola Street, Gbagada, Lagos / 601 Pennsylvania Avenue NW South Building Suite 920, Washington D.C. 20004, USA
• By Email:company@termii.com

We will respond to all requests, inquiries, or concerns within fourteen (14) working days.