Policies

Introduction

Mobility Arts Nigeria Limited is a mobile Internet Company. We offer a wide range of entertainment Value Added Service (VAS) which cut across:

• Mobile Applications
• Mobile Gaming application
• m-Health
• m-Education
• Specialized CRBT content
• SMS subscription services

Mobility Arts develops, maintains, and hosts services for delivery over Mobile operator networks with a concentration on partnering strategically with Mobile Operators in building their Mobile Value Added Services business.

Our corporate culture is founded upon uncompromising quality, value, reliability, consistent positive client experiences, total accountability and exceptional service delivery. Our team consists of talented professionals with a broad range of experience and skills in the Mobile communications Industry. We are able to create, implement and support mobile entertainment campaigns that generate revenue rapidly. We are 100% focused on taking the smart device driven world to the limits.

Purpose of the Code

This Code of Practice:

• Describes the main services we will provide to customers.
• Explains how to contact us about these services and how you can subscribe to our services.
• Explains the customer’s Rights and obligations.

Describes how to channel a complaint, how we will resolve it, and what you can do if you are not satisfied with our response.

Application of the Code

This Code applies to the provision of value added services to the telecommunications industry and has been developed by Mobility Arts Nigeria Limited in line with the established and published NCC’s General Code of Practice.

Code Administration

The Code will be administered by Mobility Arts Nigeria Limited in line with guidelines from NCC as well as reviews that are to be communicated by the Commission based on feedback from Consumer Forums that may be set-up by NCC from time to time.

Code Amendment

Mobility Arts Nigeria Limited may amend this Consumer Code from time to time to conform to set guidelines that may be required by Law or by the NCC.

1. Provision of Information to Customers

Separate minimum periods will apply to the services we present depending on the pricing option and services chosen. The minimum service duration or period of service for some of our services will be a daily request while the maximum period of service will be 30 days (renewable on expiry). The service will begin and the minimum period starts on the day you purchase the service via SMS, WAP or USSD as activation is done instantaneously.

Please note that Mobility Arts’s services are available in all parts of Nigeria with network coverage. However, our services are network dependent and certain services may not be available on all networks.

• Description of Services

We offer a range of entertainment Value Added Service (VAS) which are accessible to users via SMS and web portals. We offer:

Football Gist Which is a mobile content-based subscription service that updates subscribers’ real time with news or gossip on the go. It could be team news, transfer gossip, and pre/post match events for popular Football events. Subscribers receive SMS with URLs that point to the full stories on the news portal as the news breaks.

Entertainment Gossip a mobile content-based subscription service that updates subscribers’ real time with news or gossip on the go. It could be celebrity gossip, music, and TV events etc. Subscribers will receive live feeds with URLs to the full stories on the news portal as the news breaks.

The services are available via the following activation channels:

• SMS
• USSD
• Web

How it works:

• Subscriber will send the appropriate keywords to the designated short code 50031
• Subscriber will receive a prompt to confirm they want the service.
• Once confirmed the system automatically subscribes them to the service.

• Service Contracts & Duration

Prior to requesting for any of our services, kindly take time to read our Terms and Conditions. These terms explain how we provide our services to you and outline the agreement between us and also specifies the duration the service contract is active. If there’s any difference between our Service Contract and the Consumer Code of Practice, the Service Contract shall take precedence. You can find a copy of our standard Service Terms on our website:

https://mobilityarts-ng.com/policies/#1465584418131-c1e74eb7-cd02

• Service Subscription

Our services Football Gist and Entertainment Gossip are a mobile content-based subscription service that updates subscribers’ real time with news or gossip on the go. Subscribers receive SMS with URLs that point to the full stories on the news portal as the news breaks.

The services are available via the following activation channels:

• SMS
• USSD
• Web

How it works:

• Subscriber will send the appropriate keywords to the designated short code 50031 or dial the short code in the case of USSD
• Subscriber will receive a prompt to confirm they want the service.
• Once confirmed the system automatically subscribes them to the service.

For subscription via web the users are:

• Presented with advertising banners as the browse the internet.
• Users who opt-in after double consent and are re-directed to a landing page that guides them through an activation process specified by their mobile network carriers. This process presents the billing option and service duration to the subscribers.
• Once successful, confirmation SMS is sent the subscriber’s MSISDN.

• Contract Terms and conditions

“Introduction Welcome to Mobility Arts Nigeria Limited. These Terms and Conditions (“T&Cs”) govern your use of our content services. By subscribing to or using our services, you agree to these T&Cs. Please read them carefully before proceeding.

• Eligibility The service is available to individuals aged 18 or older. Users under 18 must obtain parental or guardian consent to use the service.
• Subscription and Consent By subscribing, you provide explicit consent to receive SMS messages from Mobility Arts Nigeria Limited. Subscriptions are activated when you opt in by texting the designated keyword to 50031, dialing the designated short code 50031or or clicking on our advertised banners via the web.
• Contract Duration The contract starts and terminates when you subscribe and unsubscribe from any of our services.
• Costs and Charges Premium message and data rates may apply as determined by your mobile network provider.
• Privacy and Data Protection Your personal data is collected, stored, and used 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 customers, and how we use it. We do not share your data with third parties without your consent unless required by law.

We will use the information provided to:

• Process subscription request placed by consumers like service account creation.
• Charge for services we provide.
• Publish consumer details in a secure directory or to provide information to NCC and other authorized government agencies.
• Communicate with the consumer about how to use the service and let them know about any changes to their service or subscription status.
• Market our own products and services.
• Carry out anonymous market research and analysis on our products and services for future service enhancements and other industry trend measurements.
• 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.

• Service Availability The service’s availability depends on your mobile network provider coverage. Mobility Arts Nigeria Limited is not responsible for delayed or undelivered messages due to network issues or other factors beyond our control.
• User Responsibilities You agree to provide accurate information and to use the service responsibly. Misuse of the service, such as sending spam or inappropriate content, is prohibited.
• Amendments and Updates Mobility Arts Nigeria Limited reserves the right to amend these T&Cs. Users will be notified of significant changes via SMS or email. Continued use of the service constitutes acceptance of updated terms.
• Refunds and Complaints Refund requests will be reviewed on a case-by-case basis. To request a refund or lodge a complaint, contact our support team at customercare@mobilityarts-ng.com. Complaints will be acknowledged within 48 hours and resolved promptly.
• Termination We reserve the right to terminate your subscription for non-compliance with these T&Cs, misuse of the service, or non-payment of applicable fees.
• Liability Limitation Mobility Arts Nigeria Limited is not liable for direct, indirect, or incidental damages resulting from your use of the service.
• Governing Law These T&Cs are governed by the laws of the Federal Republic of Nigeria. Any disputes will be resolved under the jurisdiction of the courts in Federal Republic of Nigeria.
• Contact Information For questions or support, contact us at:
• Email: enquiries@mobilityarts-ng.com and customercare@mobilityarts-ng.com

By subscribing to our services, you confirm your acceptance of these Terms and Conditions.

Thank you”

• Policy on Opt in and Opt out

Customers will be able to subscribe to our services by texting a pre-defined keyword to a short code, or dialing the short code in the case of USSD or clicking on a web banner in the case of web activation. They will be able to unsubscribe from such services by texting ‘STOP <keyword>’ to the short code of the particular service from which they wish to unsubscribe from irrespective of which channel they used to opt-in. All un-subscription messages will be free of charge.

2. Advertising And Representation Of Services
   • 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.

• Availability of service

Mobility Arts shall make clear in advertising materials which promote the availability of a service any geographical or technical limitations on the availability of the service to consumers. Mobility Arts will also make clear in advertising materials if services offerings are limited to:

1. A particular group of people;
2. A partial zone, region or other geographical area within the country;
3. A particular period of time; or
4. Through the limited availability of equipment, facilities or other materials.

Mobility Arts services may 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 coverage is available.

• Advertising of Packaged Services

Where Mobility Arts Limited represents in advertising materials that a service is provided as part of a package, Mobility Arts Limited shall ensure it is able to supply all components of the service package. In the event that Mobility Arts Limited is or may be unable to supply any component of the package, appropriate information about this limitation shall be included in the advertising materials. Where advertising materials indicate the price of a component of a service package, Mobility Arts Limited shall include in the advertising materials a statement of the minimum total charge for the package, and indicate any conditions that may apply to obtain the component at the stated price.

• Disclaimer

To ensure clarity, transparency, and compliance while protecting both the company and the subscribers, Mobility Arts LTD will:

• Clearly state the purpose and type of service being offered.
• Communicate Costs and Charges
• Provide option for opt-in consent and opt-out instructions.
• Reference relevant consumer protection laws and regulations.
• Ensure a disclaimer is visible wherever the service is advertised or promoted.
• Place the disclaimer on the home page content portal.

• Tele- Marketing

SMS broadcast for any new service will only be disseminated to customers who have opted-in to receive such messages. For existing customers, the option to opt-out free of charge will always be presented to the customer and communications of VAS services must include a clear notification of the customers’ rights in this regard. Even where a customer has opted-in to receive such messages, SMS broadcast will be strictly between the hours of 8:00am and 8:00pm on any chosen day.

The content of all SMS will be in conformity with the applicable statutory and regulatory provisions. This will not be limited to messages that are politically motivated, anti-ethnic, and pornographic or sexually related messages. Our infrastructure is embedded with the technology that filters messages for unwanted content by using keywords and flags them for further action.

3. COMPLAINT HANDLING
   • Complaint Process

Mobility Arts Nigeria Limited will operate a customer service desk which will be accessible via email. Mobility Arts subscribers can contact the help desk via e-mail: customercare@mobilityarts-ng.com. Subscribers will be expected to state the service subscribed to, their mobile number, username (if any) and details of the complaint.

Resolution Time: We aim to deal with problems as quickly as possible and so our help desk’s SLA is within 48 hours. If this is not possible, the customer will be informed on how much time it will take.

• Further Recourse

Customers who remain dissatisfied with the outcome of a complaint may refer the matter to the appropriate department or personnel within the Nigerian Communications Commission (NCC) for further action.

• Data Collection and Analysis of Complaint and Outcome

Data collection Data is collected via e-mail and Mobility Arts Limited has an appropriate recording system for all complaints and the solutions. A tracking data is also maintained in a categorized manner and is usually scrutinized on a monthly basis so as to identify reoccurring issues. Mobility Arts shall also inform the customer that a record of their complaints is being stored.

Contacting the Customer When we need to contact the customer, we will use the e-mail address, mobile or fixed phone number. We will contact the customer to advice on the outcome of our investigations.

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 e-mail detailing the nature of the complaint to: internalcontrol@mobilityarts-ng.com

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.

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.

Changes to complain Handling Process We shall from time to time and as may be required by regulation to review our complaint handling process. Revised and updated information will be posted to our website.

• Retention of Records

To help us respond efficiently, our Customer Services keeps a record of any complaints we receive. This includes keeping recorded telephone conversations, and making copies of any written communications.  We will treat the records we keep as confidential and will handle them within the relevant data protection, privacy and confidentiality legislation that applies in Nigeria.  Please keep a note of the date(s) and time(s) when you’ve spoken with us about your complaint; whom you spoke to; and what they said or promised to do. If the Nigerian Communications Commission (“NCC”) becomes involved in resolving a dispute with you, we may provide them with copies of records we hold about your complaint.  We will keep the records for 24 months after a complaint is made.

• Prevention of unsolicited SMS

SMS broadcast for any new service will only be disseminated to customers who have opted-in to receive such messages. For existing customers, the option to opt-out free of charge will always be presented to the customer and communications of VAS services must include a clear notification of the customers’ rights in this regard. Even where a customer has opted-in to receive such messages, SMS broadcast will be strictly between the hours of 8:00am and 8:00pm on any chosen day.

The content of all SMS will be in conformity with the applicable statutory and regulatory provisions. This will not be limited to messages that are politically motivated, anti-ethnic, and pornographic or sexually related messages. Our infrastructure is embedded with the technology that filters messages for unwanted content by using keywords and flags them for further action.

4. Consumer obligations
   • Acceptance of Licensee Terms

Consumers shall be bound by Mobility Arts’ terms of service once service is requested for. By activating the service on the commencement date, you are deemed to have accepted our service terms.

• Service mis-use or Abuse

Consumers shall not misuse or abuse our services by, dishonestly obtaining service or using services to send messages that are obscene, threatening or otherwise contrary to applicable laws or regulation.

5. Protection of consumer information
   • Data Gathering

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

• Data Storage

How long we keep personal information will depend 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 it is necessary for the purpose we collected or processed the information. We will take due care in ensuring that personal information provided by consumers 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.

• Data Sharing

We may provide information (in response to requests from authorized law enforcement agencies) as an obligation 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.

6. CONSUMER BILLING
   • Prepaid Services

Mobility Arts Services are prepaid services billed from the subscribers airtime by the Partner Mobile Network operator. Once a service is requested for, the airtime will be deducted from the balance of the subscribers account. Unless otherwise advertised, the subscriber’s main account will be charged up front (in advance) for the duration of the service.

7. Code Compliance
   • Our Responsibility

Mobility Arts will take its responsibility to the code compliance very seriously and will recognize the importance of developing and maintaining the Code that is approved by the commission. The company will be 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.

• Compliance Monitoring and Reporting by the Commission

Mobility Arts will fully support and work with the Commission as well as customers to ensure that the service it delivers in terms of quality of experience and customer support continues to meet and exceed industry standards and codes of conduct.

• Consumer Complaints

All complaints by consumers will first be lodged and dealt with by Mobility Arts Nigeria Limited 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 Mobility Arts for resolution in accordance with our complaint handling process detailed in this Code.

• 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. All Industry complaints will be lodged directly with the Commission. Where an Industry complaint is lodged with a Licensee, without evidence that the complaint has been lodged with the Commission as well, the Licensee shall forward a copy of the complaint to the Commission without delay, and will notify the complainant duly.

• Commission Investigation

The Nigerian Communications Commission (NCC) is empowered by law and is fully responsible for ensuring compliance as well investigation into complaints or breaches of the code by either Mobility Arts Nigeria Limited, her customers or between Mobility Arts Nigeria Limited and other providers.

• 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.

• 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 etc. Any such disclosure will be strictly controlled and will be made fully in accordance with the laws of the Federal Republic of Nigeria.