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INDIVIDUAL CONSUMER CODE OF PRACTICE

FOR

AUTOMATED VEHICLE TRACKING SERVICE By PRIMETRACK TELEMATICS NIGERIA LIMITED

AS APPROVED BY:

1.  INTRODUCTION

PRIMETRACK TELEMATICS NIGERIA Limited is a licensed telecommunications company licensed for Value Added Automated Vehicle Tracking and regulated by the Nigerian Communications Commission (NCC). In subsequent pages of this document , we shall shorten the name of the company to PTNL.

At PTNL, we consider professionalism, service excellence and corporate integrity to be the hallmark of long-term success which ultimately contributes to the ethical wellbeing of all stakeholders. We hold corporate ethics in high esteem, and we have in place systems and processes to ensure compliance with all anti-bribery and corruption laws. Amongst our most fundamental operating principles are adherence with all policies, processes, laws and regulations applicable to our line of business.

This Code of Practice is prepared and issued pursuant to the Consumer Code of Practice Regulations 2007. The matters which the Code aims to address shall include but are not limited to the under listed matters:

  1. Reasonable meeting of Consumer requirements
  2. Handling Consumer complaints and disputes
  3. Consumer compensation in case of breach
  4. Protection of information
  5. Billing

2.  DEFINITIONS & INTERPRETATIONS

Unless otherwise defined, or the context otherwise requires it, expressions defined in the General Consumer Code of Practice shall have the same meanings in this document including recitals and schedules:

2.1 “Quality of Service Regulation” means the Quality of Service Regulations 2013

2.2 “Consumer ” means the customer

3.  PROVISION OF INFORMATION TO CONSUMERS

3.1 PTNL shall, upon request, provide a copy of the contract or agreement for the provision of services and such contracts shall be in clear language that is easily understandable

3.2 Copies of duly approved individual Code shall be available to consumers upon request

4.  DESCRIPTION OF SERVICES

4.1 PTNL manages all aspects relating to VAS Automated Vehicle Tracking:

Business Fields, Products… and what we do

  • Automated Vehicle Tracking
  • Fleet Management
  • Field Service Management
  • Tracking & stolen vehicle recovery assistance

5.  PRICING INFORMATION

5.1 Contract shall not take effect until parties mutually agree on the pricing and composition thereof. Pricing components may include but not limited to applicable rates or charges, calculation basis of each charge element, frequency, or basis of the collection of the charge, information as to whether charges are subject to change and the frequency of such changes and how information on such matters shall be communicated to the Consumer.

6.  CONTRACT TERMS AND TERMINATION

6.1 Installation contracts with Consumers shall incorporate standard clauses relating to commencement date, minimum contract term (where applicable), manner and consequences of premature termination and calculation basis for payment of any penalty therefrom, situations where early termination may be permitted, renewal terms, installation, connection and decommission terms, and refund policies. In addition, all terms and conditions of a contract regarding the provision of any of our services shall be clearly stated in the contract or agreement in clear and plain, easy-to-understand language.

7.  PRODUCT WARRANTIES AND MAINTENANCE

7.1 Where applicable, PTNL shall inform the consumer of any contractual warranty relating to any shared infrastructure. Such information, where applicable, shall include how to obtain such warranty services

7.2 There shall be specific information to the consumers on the availability and provision of any maintenance service by the host party

8.  PROVISION OF SERVICES

8.1 Provision of services by PTNL shall be in accordance with the service supply time targets set out in the NCC Quality of Service regulations annexed to this Code. However, PTNL shall not be liable for any delays or refusals of service requests, lack of site availability or infrastructure availability which is beyond its reasonable

8.2 Further to clause 1 above, PTNL shall bear no responsibility for installation delays or refusals where such is attributable to the lack of credit worthiness of the Consumer.

9.    FAULT, REPAIR AND SERVICE INTERRUPTION

9.1 Relevant facilities and processes shall be implemented to ensure reporting of faults 24 hours a day by Consumer

9.2 The standard of fault repair as set out in the annexed Quality of Service regulations shall apply to the fault repair standards established by the host

9.3 PTNL shall endeavor to give adequate notification of any planned downtime including details of the disruption or outage, the services and service areas affected and any corresponding compensation or other remedies if applicable

10.  AVAILABILITY OF SERVICE

10.1 PTNL shall ensure that marketing presentation materials to potential Consumers indicate any known geographical or technical limitations which may substantially affect the performance of the Consumer services

10.2 In addition to the above, marketing materials must indicate any limitations which restrict a particular group of persons, geographical area, particular period of time or limited availability of infrastructure or other

11.           ADVERTISING OF PACKAGED SERVICES

11.1 The consumer shall be entitled to the supply of all components of a serviced package where the host has marketed the provision of its service as part of a package

11.2 Appropriate information to potential Consumer shall be included in marketing materials by PTNL where it may be unlikely to supply any component of the service package

11.3 The marketing materials may contain information on the pricing of the component of a service package; where this is so, the marketing materials shall also incorporate an estimate of the minimum total charge for the package and indicate any terms and conditions applicable to obtaining the component at the stated price

12.                    BILLING INFORMATION

12.1 The following information shall be contained in invoices issued to the Consumer:

12.2 Consumer name and billing address PTNL current business name address and registered number • Unique identification or invoice number • Date of invoice and billing period • Description of the services provided by PTNL for which consumer is charged • Historical summary of charges including total amount billed, applicable credits, advance payments or discounts, net amount payable by Consumer or repayable by Host as the case may be • Payment/refund due date • Method of payment • Method of contact for complaints and billing inquiries

13.  ITEMIZATION OF CHARGES

13.1 PTNL shall ensure that consumers have access to itemize details of all charges either on the bill or on a separate statement provided to the Consumer upon request

14.  TIMING FOR ISSUANCE OF BILL

14.1 PTNL shall issue bills and include all charges incurred within the specified billing period within 30 days of the closure of each billing

14.2 Exceptions may occur whereby all charges are not included on the invoice as a result of separate agreement between parties, or any other

15              RECEIPT AND CONSUMER PAYMENT ADVICE

15.1 PTNL shall make available appropriate and accessible methods of verification of bill payment by the

16  BILLING FREQUENCY

16.1 Consumer shall be provided with sufficient and advance written notification of any proposed changes to the billing period. The advance written notification shall be deemed sufficient by parties where it provides a minimum notification period of twice the usual billing period(s).

17  NON-PAYMENT OF BILLS

171 In the event of non-payment of bills by Consumer, PTNL shall take necessary measures (which includes but not limited to referring the issue of non- payment by the consumer to the NCC) to effect such payment or disconnect the consumer’s equipment.

17.2 Necessary measures as referred to above shall be commensurate and not unduly discriminatory

18.  INFORMATION TO CONSUMERS

18.1 PTNL shall ensure that its complaints procedure is accessible in various media and formats or as directly specified by the NCC from time to time. Information on the complaints procedure shall include:

  • Consumers right to lodge complaint
  • Mode of lodging the complaint to the Host • Requisite documents required to lodge a valid complaint • Means to track/enquire on status of complaint

18.2 The procedure must be expressed in clear language and the Consumer must be able identify how to lodge a complaint either physically or via dedicated online platforms

18.3 Consumer complaints shall be duly recorded and processed in accordance with identified practices and procedures

19.  SPECIAL NEEDS

19.1 Adequate provisions shall be made by PTNL to ensure that people with special needs are able to access the complaint handling processes

19.2 PTNL shall use its best endeavours to provide reasonable assistance to Consumer who may request assistance with lodging complaints

20.  COMPLAINT PROCESS

20.1 Complaints shall be acknowledged by PTNL verbally or in writing but preferably in the mode or manner requested by the Consumer complainant. Consumers are free to escalate complaints using many channels:

Operations Hotline1 : 08030609099 Operations Hotline2: 08033636033

Email: admin@primetracknigeria.net

The customer can also come directly to the office : Mondays – Friday (9am – 5pm) excluding public holidays .

Consumer also has access to key management personnel who can be contacted on their direct mobile numbers and/or social media accounts

CUSTOMER HELPDESK CONTACTS

  • Managing Director (08064401656)
  • Chief Technical Officer (08033636033)
  • Chief Marketing Officer1 (08030609099)
  • Chief Marketing Officer2 (08107267434)

20.2 Where possible, the Consumer shall be provided with an expected outcome or estimated timeframe within which the complaint shall be investigated and resolved. Notwithstanding the forgoing, complaints including those which require further recourse for lack of acceptable resolution, shall be acted upon within the set time frame as directed by the NCC from time to time or as provided in the annexed Quality of Service Regulations and this shall not exceed a period of three calendar months

20.3 An identified escalation process shall be accessible to the Consumer where Consumer is dissatisfied with the outcome of a complaint resolution. Such escalation process shall involve further complaint examination by a suitably qualified authorized representative of the

20.4 Consumers shall be duly informed where resolution via the escalation process has been exhausted and there are no further escalation processes.

20.5 Oral or non-written complaints shall be deemed acknowledged by PTNL at the time such was communicated to PTNL

21.    CHARGES

21.1 PTNL Complaint handling processes shall be provided free of charge. However, any complain that requires the retrieval of records more than Twelve(12) months shall attract charges which the consumers must be informed and agreed to.

22.    FURTHER RECOURSE

22.1 In addition to the complaint process set up by PTNL, the consumer reserves the right to escalate unsatisfactorily resolved or unresolved disputes to the Nigerian Communication Commission (NCC)

22.2 PTNL shall inform consumer after 60 days of non-resolution of the complaint to the satisfaction of consumer to proceed to refer the complaint to the NCC

23.    ACTION ON DISPUTED CHARGES

23.1 Where a Consumer has initiated a complaint through the laid down process and investigation is ongoing, PTNL shall be estopped from taking any action with regard to credit management action or disconnection of installed equipment or related apparatus pending the resolution of the

24.    INTERNAL DATA COLLECTION AND ANALYSIS

24.1 PTNL shall ensure availability of appropriate recording system for complaints and outcomes which shall comply with the requirements of the Commission’s Quality of Service Regulations such that recurring issues are easily tracked for effective processing

25.    CHANGES TO COMPLAINT HANDLING PROCESS

25.1 PTNL shall ensure that Consumer is properly updated with any information regarding the changes in the Company’s complaint handling process, if any

26.    RETENTION OF RECORDS

26.1 Information collated and recorded by Host in respect of the complaint handling procedure initiated by the Consumer shall be retained for at least twelve(12) months following resolution of Consumer complain.

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