Consumer Code of Practice

247 Comcare Limited is committed to providing clear, transparent, and accurate information to all subscribers across its Value-Added Services (VAS).

All service details, including pricing, subscription duration, opt-in/opt-out procedures, and customer support will be provided through:

• SMS notifications
• USSD menus
• IVR prompts
• Web/WAP pages
• Customer care channels
• Approved marketing materials

All information will comply with NCC Consumer Code of Practice Regulations, VAS Guidelines, and all applicable regulatory directives.

a. Description of Services

247 Comcare offers a portfolio of mobile VAS designed to enhance digital experiences for subscribers across mobile networks in Nigeria. Services include:

• Interactive Trivia & Gaming Services

  (Football Zone, Music Trivia, WordPlay, educational quizzes, skill-based games)

• Mobile Content Subscription Services

  (Entertainment, lifestyle, motivational content, tips, devotionals, educational content)

• Alerts & Information Services

  (Fact-of-the-day, health tips, productivity messages, inspirational messages)

• Digital Learning & Micro-Training Content

All services are delivered using approved shortcodes and in partnership with licensed aggregators and Mobile Network Operators (MNOs).

b. Service Contract, Duration & Pricing Structure

247 Comcare provides subscription-based and on-demand services with clearly defined service durations.

All subscriptions are fixed-duration and terminate automatically once the duration elapses. Users may subscribe again if they wish to continue service access.

c. Service Subscription

247 Comcare complies fully with NCC's Double Opt-In (DOI) requirement for all subscription services.

All subscriptions begin only after the user clearly confirms interest and acknowledges the service price and duration.

Subscription Process

Subscribers may opt in through SMS, USSD, IVR, or Web/WAP as follows:

d. Contract Terms & Conditions

• ✓Subscribers will receive clear information on service nature, pricing, and duration before opting in.
• ✓All services run for fixed periods and terminate automatically.
• ✓No user will ever be subscribed without explicit DOI confirmation.
• ✓All billing is communicated transparently and in line with NCC standards.
• ✓247 Comcare will ensure full compliance with NDPR and NCC data privacy and protection requirements.
• ✓Complaints will be handled promptly following NCC Consumer Code of Practice timelines.
• ✓247 Comcare reserves the right to modify or suspend services based on regulatory directives or network conditions but will always inform subscribers accordingly.

e. Opt-In and Opt-Out Procedures

247 Comcare ensures that all service promotions, representations, and communications are truthful, accurate, and compliant with NCC's Consumer Code of Practice and VAS Advertising Guidelines. All advertisements will clearly state the nature of the service, applicable pricing, and subscription requirements.

a. Availability of Service

• All advertised services will be available, functional, and accessible through approved channels (SMS, USSD, IVR, Web/WAP) at the time of promotion.
• If a service becomes temporarily unavailable due to network, system maintenance, or regulatory reasons, subscribers will be informed accordingly.
• 247 Comcare will not promote or market any service that is not live, approved, or ready for end-user access.

b. Advertisement of Packaged Services

Where services are offered as bundles or packaged content, the advertisement will clearly state:

• The type of services included
• The validity period
• The subscription price
• Any usage limitations

Packages will not contain misleading claims or hidden charges. All bundled service promotions will follow NCC pricing transparency rules.

c. Disclaimer

• 247 Comcare will include appropriate disclaimers in all service communications and advertisements.
• Disclaimers will clarify:
  • That subscription charges apply only after the subscriber's confirmation
  • That service content is for informational/entertainment purposes
  • That network availability may affect delivery time or continuity
• Disclaimers will be written in clear and simple language as required by NCC.

d. Tele-Marketing

• Any tele-marketing activity (SMS campaigns, outbound dialling, IVR calls, or promotional messages) will strictly comply with:
  • NCC Consumer Code of Practice
  • DND (Do-Not-Disturb) directives
  • Anti-Spam regulations
• Only subscribers who have permitted marketing communication will be contacted.
• All tele-marketing messages will clearly state: The service being offered, Pricing, Duration, How to subscribe, and How to opt out of further promotional messages.

247 Comcare is committed to providing effective, timely, and transparent complaint-resolution processes in line with the NCC Consumer Code of Practice Regulations. All complaints will be handled professionally and resolved within the timelines prescribed by the Commission.

a. Complaint Processes

Subscribers may lodge complaints through any of the following channels:

On receipt of a complaint:

1. Acknowledgment is provided immediately or within the same day.
2. Investigation begins promptly with details recorded.
3. Resolution is provided within NCC-specified timelines.
4. Feedback is communicated to the subscriber in clear, simple language.

Complaints may include issues related to billing, service access, delays in content delivery, or opt-in/opt-out confirmation errors.

b. Further Recourse

If a subscriber is dissatisfied with the outcome of a complaint, they will be informed of additional escalation options:

1. Internal escalation to a supervisor or senior customer service personnel
2. Escalation to the Mobile Network Operator (MNO) or Aggregator
3. Further escalation to the Nigerian Communications Commission (NCC), in accordance with the Commission's Consumer Complaint/Dispute Resolution Framework

c. Data Collection and Analysis of Complaints

• 247 Comcare will maintain a structured system for collecting, categorizing, and analyzing all complaints received.
• The data will track: Nature of complaints, Root cause, Time to resolution, Corrective actions taken, Frequency of repeat complaints
• The analysis will be used to identify trends, improve internal processes, and prevent recurring issues.

d. Retention of Records

• All complaint records including logs, resolutions, timestamps, and correspondence will be retained for a minimum of 24 months or as required by NCC regulations.
• Records will remain accessible for audit, regulatory review, or dispute resolution.
• Stored information will be handled in compliance with NDPR and NCC Data Protection Guidelines.

e. Prevention of Unsolicited SMS

247 Comcare is committed to eliminating unsolicited communications. Measures include:

• Strict enforcement of Double Opt-In (DOI) before any service activation
• No marketing or promotional SMS to users on the Do-Not-Disturb (DND) list
• Ensuring all marketing campaigns are permission-based
• Clear "STOP" instructions included in promotional SMS where applicable
• Regular audits with aggregators and MNOs to ensure adherence to anti-spam guidelines

To ensure a smooth experience across all 247 Comcare services, consumers are expected to:

• •Provide accurate information when subscribing to any service.
• •Use services responsibly and in accordance with Nigerian laws and NCC regulations.
• •Safeguard their mobile devices and SIM cards to prevent unauthorized access or misuse.
• •Review all subscription messages, including pricing, duration, and confirmation prompts, before opting in.
• •Keep their contact information updated to ensure proper receipt of service notifications.
• •Follow provided opt-out procedures when they wish to discontinue a service.
• •Report any suspected unauthorized subscription, billing error, or service issue promptly via approved customer care channels.

247 Comcare is committed to safeguarding consumer data in compliance with the Nigerian Data Protection Regulation (NDPR) and NCC Data Protection Guidelines. All consumer information is handled lawfully, transparently, and securely.

a. Data Gathering

• Consumer data is collected only for lawful business purposes such as service delivery, billing, customer verification, complaint handling, and regulatory reporting.
• Information collected may include:
  • MSISDN (phone number)
  • Subscription timestamps
  • Service preferences
  • Complaint records
  • User consent logs (DOI records)
• No data is collected without subscriber knowledge or in violation of NCC consent requirements.

b. Data Storage

• All consumer information is stored in secure, access-controlled environments with encryption and industry-standard security safeguards.
• Access to data is restricted to authorized personnel strictly on a need-to-know basis.
• Data retention follows NCC and NDPR requirements.
• Data is stored only for as long as necessary to fulfill service obligations, comply with legal mandates, or resolve disputes.
• Adequate measures are in place to prevent:
  • Unauthorized access
  • Data loss
  • Alteration
  • Breach

247 Comcare conducts periodic security reviews to maintain data integrity.

c. Data Sharing

• Consumer data will not be sold, traded, or shared with unauthorized third parties.
• Data may be shared only under the following conditions:
  1. With Mobile Network Operators (MNOs) or licensed Aggregators solely for service delivery and billing.
  2. With regulators such as NCC when formally required for compliance or investigations.
  3. With law enforcement agencies upon receipt of valid legal requests.
  4. With service partners strictly when necessary to deliver a subscribed service and only under confidentiality and data protection agreements.
• Any third party that receives consumer data must comply with NDPR, NCC guidelines, and equivalent security standards.

247 Comcare ensures that all billing practices are transparent, accurate, and fully compliant with NCC regulations. All charges are applied only after a subscriber has provided explicit consent through the Double Opt-In (DOI) process.

a. Billing Information

• All billing information (price, duration, type of service, and charge type) will be clearly communicated before subscription.
• Billing information will appear in:
  • DOI confirmation messages
  • USSD/Web interfaces
  • IVR prompts
  • Welcome messages
• All charges will be presented in Nigerian Naira (₦) and in straightforward, non-misleading language.

b. Timing for Issuance of Bill

247COMCARE shall process and issue bills within 10 days of the closure of each billing period. A bill shall include all charges incurred during the billing period except where:

• Billing occurs immediately after the subscriber confirms the subscription via DOI except for services with free trials.
• For services that rely on mobile network billing (DCB), charges are processed instantly once authorization is completed.
• Subscribers receive confirmation of successful billing within seconds via SMS.
• No charge is applied before confirmation, and no charge is applied after the service duration expires unless the user initiates a new subscription.

c. Payment Confirmation

Immediately after billing, subscribers receive an SMS containing:

• Confirmation of successful payment
• Name of service subscribed to
• Amount charged
• Duration of access
• Opt-out instructions (if applicable)

d. Billing Frequency

247COMCARE shall provide Customers with advance written notification of any proposed changes in billing periods, such advance notification to be at least equal to two (2) of its otherwise applicable billing periods (i.e. at least 2 months in advance where the billing period being changed is monthly).

e. Prepaid Services

All 247 Comcare VAS products operate strictly as prepaid services, with charges applied only after the subscriber has confirmed interest.

However, certain services may include a one-day free trial period to allow subscribers evaluate the service and decide if they wish to continue.

• For services with a free trial, subscribers will be clearly informed during the DOI process that:
  1. The first day is free
  2. The applicable charge will apply only after the free trial expires if the subscriber chooses to continue
• Outside of free-trial services, all subscriptions remain fully prepaid; subscribers are billed before accessing the service, not afterward.
• 247 Comcare does not offer postpaid or credit-based billing for any VAS product.
• Subscribers are always informed of the exact service cost, duration, and terms before confirming the subscription.