KTRefill (“KTRefill,” “we,” “us,” or “our”) is a brand and digital telecommunications and services platform operated by KT Empire Ltd, a company registered in the United Kingdom and Nigeria. This Privacy Policy explains how we handle personal information when you use our website, applications, products, and related Services.
01Information We Collect
We collect information you provide, information generated through your use of the Services, and information received from third-party providers where necessary to provide our Services.
Information You Provide Directly
Depending on the Services you use, we may collect:
- Full name, email address, phone number, and account login information.
- Billing information, delivery address, and order and transaction details.
- Recipient phone number, name, and other recipient information.
- Mobile carrier, country, and eSIM or SIM-related information.
- Information provided when contacting customer support or through forms and messages.
Payment Information
Third-party payment providers, banks, and financial service providers may process payment information directly. KTRefill generally does not store complete payment card numbers or full payment credentials. We may receive transaction reference, payment status, method, currency, amount, provider, and partial payment details.
Information Collected Automatically
We may collect IP address, browser and device information, operating system, approximate location, language, timezone, pages viewed, referring pages, time spent, clicks, interactions, and cookie information. Approximate location may help provide currency, product, carrier, or regional availability detection.
02Information From Analytics and Advertising Technologies
We may use analytics, advertising, and measurement technologies provided by third parties, including Google Analytics and the Meta Pixel. These technologies may collect information about your device, browsing activity, interactions, and advertising activity.
We use this information to understand visitors, improve our website and Services, measure advertising performance, understand how customers discover KTRefill, improve campaigns, and deliver or measure relevant advertising where permitted. Where consent is required, we will request it through our cookie or consent-management tools.
03Cookies and Similar Technologies
KTRefill uses cookies and similar technologies to operate and improve the Services. Cookies may keep you signed in, maintain your shopping session, remember currency preferences, maintain security, understand usage, measure advertising performance, and support marketing and analytics.
Some cookies are necessary, while others may be optional. Where required by law, we will provide choices regarding non-essential cookies. You can manage cookies through your browser settings, although disabling certain cookies may affect functionality.
04How We Use Your Information
We may use personal information to:
- Create and manage accounts, process and fulfill orders, and deliver airtime, eSIMs, SIM cards, gift cards, and other Services.
- Process payments, confirm transactions, provide support, and send service-related notifications.
- Detect, investigate, and prevent fraud and unauthorized activity.
- Protect platform security, improve products and customer experience, and analyze usage and performance.
- Measure marketing campaigns and send promotional communications where permitted and, where required, with consent.
- Comply with laws, establish or defend legal claims, and protect the rights, safety, and property of KTRefill, KT Empire Ltd, customers, and third parties.
05Legal Bases for Processing
Depending on the circumstances and applicable law, we may process personal information on the following bases:
Contract
Information necessary to provide requested products and Services, process orders, and manage your account.
Legal Obligations
Information necessary to comply with legal, regulatory, tax, accounting, fraud-prevention, or other requirements.
Legitimate Interests
Information necessary for fraud prevention, security, service improvement, support, and protecting our rights, provided those interests are not overridden by applicable privacy rights.
Consent
Where required by law, we may request consent for marketing, advertising, or non-essential cookies. You may withdraw consent at any time, without affecting earlier processing.
06How We Share Your Information
We do not sell your personal information. We may share information with trusted third parties where necessary to provide Services or operate our business, including payment providers and banks; mobile carriers, eSIM, SIM, airtime, and gift-card fulfillment partners; hosting, cloud, security, support, analytics, communications, and software providers; analytics and advertising providers such as Google and Meta; professional advisers; and government, regulatory, law enforcement, or court authorities where required or reasonably necessary.
07Information About Other People
Some Services require information about another person, such as an airtime, SIM, eSIM, or gift-card recipient. If you provide another person’s information, ensure you are authorized to do so and, where required, that the person understands how it may be used.
We use recipient information only as reasonably necessary to provide the requested Service, comply with legal obligations, prevent fraud, and protect our business and customers.
08International Data Transfers
KT Empire Ltd is registered in the United Kingdom and Nigeria, and KTRefill works with providers and partners in different countries. Personal information may therefore be transferred to, stored in, or processed outside the country where you live.
Where applicable law requires safeguards, we will take appropriate measures, which may include contractual safeguards, adequacy arrangements, or other legally recognized transfer mechanisms.
09Data Retention
We retain personal information only as long as reasonably necessary for the purposes described in this Policy. Retention may depend on the type and sensitivity of information, why it was collected, how long we need it to provide Services, legal, tax, accounting, regulatory, fraud-prevention, security, dispute, and agreement-enforcement requirements.
When information is no longer required, we will take reasonable steps to delete, anonymize, or securely dispose of it.
10Data Security
We use reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. Measures may include access controls, security monitoring, encryption where appropriate, and reputable infrastructure and service providers.
No transmission or electronic storage method is completely secure, so we cannot guarantee absolute security.
11Your Privacy Rights
Depending on your location and applicable law, you may have the right to access, correct, delete, restrict, or object to processing; withdraw consent; request portability; object to direct marketing; and lodge a complaint with a relevant data protection authority.
Nigeria
Where applicable, rights may be protected under the Nigeria Data Protection Act and other Nigerian privacy laws. You may have the right to complain to the Nigeria Data Protection Commission.
United Kingdom
Where applicable, rights may be protected under the UK GDPR and Data Protection Act 2018. You may have the right to complain to the Information Commissioner’s Office.
12Marketing Communications
We may send service-related communications necessary to process or manage orders and accounts. Where permitted, we may also send promotional communications. You can unsubscribe using the instructions in the communication, by contacting us, or through account preferences.
Even if you opt out of marketing, we may continue sending essential transactional or service-related messages.
13Children’s Privacy
Our Services are not intended for individuals under 18. We do not knowingly collect personal information from children in violation of applicable law. If you believe a child has provided information, contact us so we can investigate and take appropriate action.
14Third-Party Websites and Services
KTRefill may contain links to or integrations with third-party websites, applications, payment providers, carriers, or other services. We are not responsible for third-party privacy practices. Review third-party privacy policies before providing personal information.
15Changes to This Privacy Policy
We may update this Policy to reflect changes to our Services, business practices, technology, or legal requirements. When we make changes, we will update the Last Updated date. Where required by law, we may provide additional notice or obtain consent for material changes. We encourage you to review this Policy periodically.
16Contact Us
If you have questions, concerns, or requests about this Policy or how we handle personal information, contact us:
When making a privacy request, provide enough information for us to identify your account or transaction. We may need to verify your identity before completing certain requests.
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