TTP Data Protection Policy
Effective Date: December 1, 2020
1. Applicability
Employees of TTP and its subsidiaries must follow this policy. Contractors, consultants, partners, Government Agencies and any other external entity are also included.
Generally, TTP policy refers to anyone it collaborates with or anyone who acts on TTPâs behalf and may need occasional access to data.
2. Policy Purpose
TTP Data Privacy and Consent Policy refers to TTPâs commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality.
TTP ensures that it gathers, stores and handles data fairly, transparently and with respect towards individual rights.
Information TTP Will Collect
As part of TTPâs operations, TTP needs to obtain and process information. This information includes any offline or online data that makes a person or truck identifiable such as names, email, phone numbers, addresses, usernames and passwords, digital footprints, photographs, videos, financial data, etc.
TTP will collect your details and that of your truck(s) or vehicle(s) when you come into and out of designated Ports and Parks in Nigeria and when you apply to use, or are using TTPâs services.
Personal Information
Information relating to drivers, truck owners, agents, terminal operators, unions, law enforcement activities and payment information.
Truck & Vehicle Information
Details relating to trucks and vehicles accessing TTP designated ports, parks and facilities.
Images & Media
Photographs of truck drivers, trucks, parks, videos, audio materials and other legally required information.
Designated Ports and Parks
Information will be required from locations including but not limited to:
TTP collects this information in a transparent way and only with the full cooperation and knowledge of the necessary parties.
How TTP Will Use Your Information
We use the information we collect to improve our services, manage operations, maintain security, and comply with legal and regulatory requirements.
Manage access to Ports and Parks by verifying the identity of truck drivers, vehicle owners, agents, and other authorised personnel.
Enable and manage delivery of services including truck and driver scheduling, terminal operations, and park usage.
Record movements in and out of designated locations to ensure security, operational transparency, and regulatory compliance.
Process payments, manage billing issues, and maintain accurate transaction records.
Store photographs, videos, and other relevant media for auditing, compliance, and future reference.
Analyse operational data to improve platform performance, efficiency, and service delivery.
Assist with investigations or respond to lawful requests from law enforcement or public authorities.
Promote accountability among stakeholders including drivers, agents, unions, and enforcement personnel.
Deliver and manage communication services including SMS, RCS, Email, WhatsApp, and other communication channels.
Personalise user experiences and interface preferences.
Provide timely and effective customer support.
Comply with legal and regulatory obligations under Nigerian law and industry guidelines.
Information With Third Parties
Your personal information may be shared with third parties if:
- Further processing is required. This may include translation, transfer to foreign countries or international organisations in accordance with NITDA, NDPR and applicable regulations.
- TTP has a statutory duty to disclose information for legal, regulatory reasons, or public interest.
- You provide consent for the transfer of your data.
- It is necessary for the performance or conclusion of a contract between you and TTP.
- It is required to establish, defend, or exercise legal claims.
Where your personal data is shared with third parties, TTP will ensure that such third parties comply with all current data protection legislations. Where such third parties are located outside Nigeria, such organisations will process your personal data subject to the provisions of NITDA and NDPR.
Legal Basis for Processing Your Personal Data
In line with the provisions of the NDPR, processing of Personal Data by TTP shall be lawful if at least one of the following applies:
Consent
You (Data Subject) have given consent to the processing of your Personal Data for one or more specific purposes.
Performance of Contract
Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract.
Legal Obligation
Processing is necessary for compliance with a legal obligation to which TTP is subject.
Protection of Interest
Processing is necessary in order to protect your interest or that of another natural person.
Performance of Public Task
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of the official public mandate vested in TTP.
Governing Principles of Data Processing
In addition to the procedures laid down under the NITDA and NDPR or any other instrument, your Personal data collected will be processed lawfully and legitimately for the purpose it was collected only if you consent to it. Further processing may be done only for archiving, scientific research, historical research or statistical purposes for public interest.
Lawful Processing
Personal data collected by TTP will only be processed lawfully, fairly, and transparently for the purpose it was collected. Further processing will only occur where permitted for legitimate purposes such as research and public interest.
Data Accuracy & Security
TTP ensures that your data remains accurate, adequate, and protected. We apply modern technology and industry best practices to safeguard information against unauthorized access, cyber threats, damage, and misuse.
Accountability & Duty of Care
TTP remains accountable for how personal data is processed and owes every data subject a duty of care in protecting their information and privacy rights.
Data Security
TTP has in place, a range of physical and electronic security safeguards to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
Secure Data Transmission
Our website uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your Personal Data. The URL address starts with https:// depicting a secure webpage.
SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session is encrypted before transmission and decrypted at the receiving end.
Our website, ĂtĂČ app and ERP are hosted on AWS where standard AWS cloud security measures also apply.
TTP Data Protection Principles
Accuracy
Personal data collected will remain accurate and kept up-to-date.
Lawful Collection
Information is collected fairly and only for lawful purposes.
Responsible Processing
TTP processes information within legal and ethical boundaries.
Access Protection
Personal information is protected against unauthorized or illegal access from internal and external parties.
Advancement of Right to Privacy
The privacy right you have shall be interpreted for the purpose of advancing and never restricting the safeguards you are entitled to under any data protection instrument made in furtherance of fundamental rights and Nigerian laws.
Data Breach
Ensuring the utmost security of your personal data is important to us. If there is any data breach, TTP shall notify NITDA of such personal breaches within 72 hours of becoming aware of such breach.
TTP will take the required steps within the shortest reasonable time and according to relevant laws and regulations to remedy any breach.
Disciplinary Consequences
All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action against any TTP employee found wanting.
Transfer of Data to Foreign Country
Where Personal Data is to be transferred to a country outside Nigeria for business purposes, TTP shall put adequate measures in place to ensure the security of such Personal Data.
TTP shall conduct a detailed assessment to determine whether the receiving country is on the National Information Technology Development Agency (NITDA) White List of Countries with adequate data protection laws.
Data Encryption
Personal Information shall be stored using Oracle Advanced Security Transparent Data Encryption format while following Generally Accepted International Security Standards (ISO).
Regulatory Compliance
Personal Information remains subject to the Nigerian Data Protection Regulation (NDPR) and other applicable Nigerian data protection laws.
Compliance With NDPR Requirements
NITDA has determined that the foreign country, territory, specified sectors, or international organisation provides an adequate level of protection.
The Attorney-General of the Federation has considered factors including the foreign country's legal system, human rights protection, public security, defence, national security, criminal law and government access to personal data.
Exceptions in Respect of Transfer of Data to a Foreign Country
Where adequate safeguards are unavailable, transfer of Personal Data may take place where one of the following conditions applies:
Consent
The Data Subject has provided consent after being informed of possible risks.
Contract
The transfer is necessary for performance of a contract between you and TTP.
Business Agreement
The transfer is required for agreements between TTP and another party.
Public Interest
The transfer is necessary for public interest purposes.
Legal Claims
The transfer is required for establishing or defending legal claims.
Vital Interest
The transfer protects the vital interests of the data subject or another person.
Your Rights
Your right to object to the processing of your data shall always be safeguarded. You have the right to:
- Request and access your Personal Data collected and stored.
- Receive information about your personal data.
- Object to processing or request restriction.
- Request correction or modification of your data.
- Request deletion of your data where legally permitted.
- Request transfer of your data to a third party.
- Object to marketing-related processing.
Exercise Your Data Rights
You can exercise any of your rights by contacting TTP through:
9th Floor, St Nicholas House
26 Catholic Mission Street
Lagos Island, Lagos State
Attention: Customer Care
Tel: +234 9072 887 887, +234 7068 243 253
Email: info@ttp.com.ng
Consent
By ticking the âI agreeâ box on this website or the ĂtĂČ mobile app, or in the electronic versions of this form or completing and signing a hard copy and returning same to TTP Customer Care Department, I declare and acknowledge that I have read this Form and TTP Data Privacy and Consent Policy and I understand same.
I further declare that to the extent that my consent is required, I grant my consent to TTP to process, disclose and retain my personal information for the purposes explained above.
By ticking the âI agreeâ box on this website or the ĂtĂČ mobile app, or in the electronic versions of this form or completing and signing a hard copy and returning same to TTP Customer Care Department, I declare and acknowledge that I have read this Form and TTP Data Privacy and Consent Policy and I understand same.
I also declare that I understand the possible risks associated with hosting data in a foreign company or international organisation, and to the extent that my consent is required, I grant consent to TTP to process and transfer my data to a foreign country or international organisation for the purposes stated by TTP in its Data Privacy and Consent Policy.
TTP complying with the rights and responsibilities herein, I waive any legal, equitable or contractual rights for any damages that I may incur as a result of the use of my data in the manner set out herein.
By providing your consent, you confirm that you have read, understood, and agreed to TTPâs Data Privacy and Consent Policy.