PINNACLE MOBILE LIMITED
CODE OF PRACTICE
PINNACLE MOBILE LIMITED CODE OF PRACTICE
PART 1: INTRODUCTION
1.1 PURPOSE OF THE CODE OF PRACTICE
Pinnacle Mobile Limited is a VAS (Value Added Service) provider based in Lagos, Nigeria and has been licensed by the Nigerian Communications Commission (NCC) to offer VAS to the telecommunications industry in Nigeria.
These codes of practice has been carefully complied and developed in accordance and compliance with the directive as published by the Nigerian Communications Commission (NCC) pursuant to section 106 of the Nigerian Communications Act 2003 and in conjunction with the Customer Code of Practice Regulations 2007. Pinnacle Mobile Code of Practice is to guarantee that our mobile subscribers and customers can use mobile services with confidence. The Code aims to furnish our customers and consumers with detailed up to date information on all services provided by Pinnacle Mobile, particularly on the pricing of these services, and a system for addressing any concerns relating to services provided by Pinnacle Mobile and our response to any complaints made by our customers.
1.2 SCOPE OF CODE THE OF PRACTICE
Unless otherwise specified, this code of practice applies to all wireless application services accessed by a customer in Nigeria, provided by Pinnacle Mobile Limited through the Nigerian Mobile Network Operators’ infrastructures.
1.3 CODE AMMENDMENT
Pinnacle Mobile Limited may from time to time amend this Consumer Code of Practice in compliance with the set guidelines as may be required by Law or by the Nigerian Communications Commission (NCC).
1.4 EXISTING AGREEMENTS WITH THE OPERATORS
Pinnacle Mobile Limited must comply with the existing contracts and agreements with the Mobile network operators as well as comply with these outline code of practice.
The following terms listed below have the following meaning throughout this document:
2.1. An “adult service” is any service where the content or product is of a clearly sexual nature, or any service for which the related promotional material is of a clearly sexual nature, or indicates directly, or implies that the service is of a sexual nature.
2.2. An “adult content service” is any service for the provision of content which has been classified as suitable only for persons 18 years or older by an appropriate body (such as the Film and Publications Board), or content reasonably likely to be so classified.
2.3. A “beneficiary” is a charity or organisation benefiting from a charitable promotion.
2.4. A “charitable promotion” is any promotion which has a primary goal of benefiting a registered charitable organisation.
2.5. A “child” refers to a natural person below 18 years of age.
2.6. A “commercial message” is a message sent by SMS or MMS or similar protocol that is designed to promote the sale or demand of goods or services whether or not it invites or solicits a response from a recipient.
2.7. A “competition service” is any competition or game with prizes or entry mechanism draw.
2.8. A “content subscription service” includes any subscription service providing or offering access to content including, by way of example only and not limitation: sound clips, ring tones, wallpapers, images, videos, games, text or MMS content or information.
2.9. A “customer” is a user of a mobile cellular telecommunications service that has indicated a willingness to access or utilise a service provided by a wireless application service provider.
2.10. An “information or service provider” is any person on whose behalf a wireless application service provider may provide a service, and includes message originators.
2.11. A “keyword” is any word used in an SMS or MMS sent by a customer to request a service.
2.12. A “message originator” is the entity sending a commercial message and can be any person or organisation with a commercial arrangement with Pinnacle Mobile to send messages.
2.13. A “network operator” is a mobile cellular telecommunication service provider, or any other category of telecommunication service provider as determined by Pinnacle Mobile
2.14. The “originating number” is the number allocated to Pinnacle Mobile by the network operator from which a commercial message is sent.
2.15. A “person” means any natural or legal person.
2.16. A “premium-rated service” is any service charged at a higher rate than the standard rate set by the network operator for that particular service.
2.17. “Spam” means unsolicited commercial communications, including unsolicited commercial messages as referred to in section 5.2.1.
2.18. A “subscription service” is any service for which a customer is billed on a repeated, regular basis without necessarily confirming each individual transaction.
2.19. “ Pinnacle Mobile website“ refers to its website located at https://www.facebook.com/pinnaclemobile
2.20. A “wireless application service provider” is any person engaged in the provision of a mobile service, including premium-rated services, who signs a WASP contract with a network operator for bearer
PART II: GENERAL PROVISION OF INFORMATION TO CONSUMERS
3.1. Service Contracts & Service levels
3.1.1. Pinnacle Mobile shall supply, or make available on request, a copy of the contract or agreement for the provision of services, and such contracts shall be written in plain and clear language
3.1.2. Pinnacle Mobile shall not offer or promise services that they are unable to provide.
3.1.3. Provision of services must not be unreasonably prolonged or delayed.
3.1.4. Pinnacle Mobile is not liable for any failure to provide a service due to circumstances beyond its control.
3.1.5. Professional and lawful conduct
3.1.6. Pinnacle Mobile Limited is deeply committed to lawful conduct at all times.
3.1.7. Pinnacle Mobile Limited shall at all time conduct themselves in a professional manner in their dealings with the public and customers.
3.1. 8.Freedom of expression
3.1.9. Pinnacle Mobile respects the constitutional right to freedom of speech and
3.2. Description of Service
We have a lot of services ranging from Caller RingBack Tunes to Ring Tones and True Tones, SMS Infotainment Content such as News, Sports, Bible, Prayer, Islamic services and a host of other services as our service catalogue expands almost daily.
For detailed description and pricing of our services, please send an email to email@example.com
3.2.1 Availability of Service
Pinnacle Mobile Services are not available on all mobile networks and as our services are network dependent, services shall be restricted to certain areas within Nigeria where mobile network service is available.
3.2.2. Before entering into a contract for any service, Customers shall be provided a complete description of the service in clear and plain language, avoiding unnecessary technical terms. Where other services are required in order to effectively utilize the service, the Customer shall be sufficiently informed of such requirements or service dependencies.
3.2.3. Pinnacle Mobile shall also provide information on the service quality levels offered, the waiting time for initial connection and any service areas and coverage maps if applicable.
3.2.4. Pinnacle Mobile shall provide specific information regarding any compensation, refund or other arrangements, which may apply if contracted quality service levels are not met, along with the procedures and methods for resolving disputes in respect of the service contract.
3.2.5. Where services are packaged with one or more other services or products,
Pinnacle Mobile shall provide the Customer in relation to each service or product:
(a) A description of each component service or product, and where Pinnacle Mobile sells the service or product component separately, the price that Pinnacle Mobile would charge for the component on a stand-alone basis; and
(b) For services that are bundled with services from third parties, Pinnacle Mobile shall be fully responsible for the effective performance of the entire package including service support, maintenance, complaints handling, dispute resolution and other administrative requirements.
3.2.6. Where services are subject to upgrade or migration options, Customers shall be provided with clear and complete information regarding the upgrade or migration terms, including any changes in service performance and any duly approved fees or charges resulting from the upgrade or migration.
3.3. Pricing Information
Pinnacle Mobile pricing shall not contain any hidden costs. Where applicable, pricing for content services shall include the cost of the content and indicate any bearer costs that may be associated with downloading, browsing or receiving that content.
3.3.1. Before a contract for service is entered into, Pinnacle Mobile shall inform the Customer of :
(a) the applicable rates or charges ;
(b) what the charges include ;
(c) each part or element of an applicable charge, and the method of its calculation ;
(d) the frequency of the charge or other circumstances that give rise to the charge ;
(e) whether, the charges or elements thereof are subject to change from time to time, the circumstances of such changes and how the Customer shall be informed of such changes.
3.3.2. Provision of information to customers
3.3.3. Pinnacle Mobile is committed to honest and fair dealings with her customers. In particular, pricing information for services shall be clearly and accurately conveyed to customers and potential customers.
3.3.4. Pinnacle Mobile shall not knowingly disseminate information that is false or deceptive, or that is likely to mislead by inaccuracy, ambiguity, exaggeration or omission.
3.3.5. Pinnacle Mobile shall make the terms and conditions of any of her services available to customers and potential customers, on request.
3.3.6. Pinnacle Mobile shall provide Customers with information on their services that is complete, accurate, and up-to-date and in simple, clean language.
3.3.7. Pinnacle Mobile shall endeavor to respond in a timely manner to Customer requests for information on services provided and such information shall be provided free of charge and shall include at least the following:
(a) Current service, arrangements, including rates and terms and conditions for all services offered to the public, shall be readily available in print and electronic format (including on Pinnacle Mobile’s web site.
(b) Services that are subject to price or tariff regulation by the Commission shall be described in service tariff pages published in an accessible form, including being made available at Pinnacle Mobile office and on its website.
(c) Where Pinnacle Mobile seeks any change in the tariff rates for services, affected customers shall be notified of the proposed price change in an effective manner that in, particular, lets them comment to the Commission on the proposed changes. After approval by the Commission, Customers shall also be notified of the resulting tariff changes in an effective manner.
3.4. Contract Terms and Termination
Prior to requesting the service, every subscriber will be expected to read our terms and conditions which details full terms under which we provide products and services to our customers. It governs the contractual relationship between us and if any discrepancy exists between the Service Contract and Consumer Code of Practice, the Service Contract shall take precedence. A copy of our standard Service Terms is available for download at our website on https://www.facebook.com/pinnaclemobile
3.4.1.The contract itself shall contain the following information regarding the term:
(a) the commencement date of the contract ;
(b) what the minimum contract term is, if applicable ;
(c) where applicable, the minimum contract period and the manner and consequences of termination;
(d) the situations where early termination is possible;
(e) the amount or method of calculating any charges payable upon early termination ;
(f) the conditions and terms of renewal of the contract, if applicable ;
(g) the conditions and terms of disconnection and reconnection and fees that may be charged for disconnection or reconnection ;
(h) terms and conditions that may apply to refund of any deposit including timing and any deductions or charges applicable ;
(i) terms and conditions relating to situations that may give rise to the interruption, withdrawal or discontinuation of the service ; and
(j) terms and conditions relating to the delivery, installation or activation of the service.
3.4.2. Before entering into a contract to provide services, Pinnacle Mobile shall inform the Customer as to whether there is any contractual warranty relating to products (if any) supplied for use in connection with the service, including how to obtain warranty service if needed and where a copy of the warranty is not provided with the products, Pinnacle Mobile shall inform the Customer how and where it is available.
3.4.3. Pinnacle Mobile shall provide specific information regarding any maintenance services offered.
3.4.4. Pinnacle Mobile shall provide services within any service supply time targets set out in the Commission’s Quality of Service Regulations, subject to the following:
(a) in the event Pinnacle Mobile encounters technical problems that interferes with provisioning of the service(s), the time for provisioning shall be subject to any time or process of rectification permitted by the Commission ;
(b) Pinnacle Mobile shall not be responsible for any readiness of premises or availability of infrastructure or equipment that is beyond its reasonable control; and Pricing information.
(c) Pinnacle Mobile shall not be responsible for delays or refusals of service requests caused by the Customer being identified as not credit-worthy.
3.5. Intellectual property.
3.5.1. Pinnacle Mobile shall respect the intellectual property rights of their clients and other parties and shall not knowingly infringe such rights.
3.5.2. Content control
3.5.3.Pinnacle Mobile shall not knowingly transmit or publish “content which is illegal or forbidden”
3.5.4. If Pinnacle Mobile becomes aware of illegal content that is under its control, Pinnacle Mobile shall immediately suspend access to that content. Where required to do so by law, Pinnacle Mobile shall report the illegal content to the relevant enforcement authority.
3.6. Data protection
3.6.1. Pinnacle Mobile shall take all reasonable measures to prevent unauthorized or unlawful access to, interception of, or interference with any data.
3.7.1. Pinnacle Mobile shall not provide any services or promotional material that:
- contains a visual presentation of explicit violent or sexual conduct;
- results in any unreasonable invasion of privacy;
- induces an unacceptable sense of fear or anxiety;
- encourages or incites any person to engage in dangerous practices or to use harmful substances;
- induces or promote racial disharmony;
- causes grave or widespread offence; or
- Debases, degrades or demeans.
3.8. Information providers
3.8.1. Pinnacle Mobile will legally bind any information provider with whom they contract for the provision of services to ensure that none of the services contravene the Code of Practice.
3.8.2. Pinnacle Mobile may suspend or terminate the services of any information provider that provides a service in contravention of this Code of Practice.
3.9.1. Pinnacle Mobile reserves the right to make alterations to this Code of Practice from time to time.
3.9.2. The current Code of Practice will always be available on the Pinnacle Mobile website.
3.10. Privacy and Confidentiality
3.10.1. Pinnacle Mobile respects the constitutional right of her customers to individual privacy and privacy of communications.
3.10.2. Pinnacle Mobile respects the confidentiality of customers’ personal information and shall not sell or distribute such information to any other party without the explicit consent of the customer, except where required to do so by law.
3.11. Fault Repair and Service Interruption
3.11. 1.Pinnacle Mobile shall implement the facilities and processes needed to permit Customers to report faults 24 hours a day.
3.11.2. Pinnacle Mobile shall comply and shall cause her agents to comply with the relevant fault repair standards set out in the Commission’s Quality of Service Regulations.
3.11.3. Pinnacle Mobile shall endeavour to give advance warning of anticipated service disruptions or planned outages, including details of the disruption or outage, the services and service areas affected and any applicable compensation or other remedies.
3.11.4. In the event of force majeure such as floods and storms Pinnacle Mobile shall endeavour to rectify the fault within such period of time as may be reasonable in the circumstances.
PART III: ADVERTISING OF PACKAGED SERVICES
- The Advertising Practitioners Council of Nigeria (APCON)
4.1. The Advertising Practitioners Council of Nigeria (APCON) regulates advertising practices in Nigeria, and has established the Nigerian Code of Advertising Practice. Pinnacle Mobile shall comply with the advertising standards established by APCON, and any other applicable laws or standards, in addition to the rules regarding the advertising or other promotion of telecommunications services set out in this Code.
- Availability of Services
5.1 Pinnacle Mobile 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 customers which:
(a) substantially affect the performance of the service; and
(b) are known to Pinnacle Mobile.
5.2. Pinnacle Mobile shall make clear in any advertising materials which promote a
service offer any limitations in the offer which restrict it—
(a) to a particular group of people ;
(b) to a partial zone, region or other geographical area within the country ;
(c) to a particular period of time ; or
(d) through the limited availability of equipment, facilities or other materials.
- Advertising of Packaged Services
6.1. Where Pinnacle Mobile represents in advertising materials that a service is provided as part of a package, Pinnacle Mobile shall ensure it is able to supply all components of the service package. In the event Pinnacle Mobile is or may be unable to supply any component of the package, appropriate information about this limitation shall be included in the advertising materials.
6.2 Where advertising materials indicate the price of a component of a service package, Pinnacle Mobile 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.
- Unsolicited Telemarketing
7.1. Pinnacle Mobile shall not engage in unsolicited telemarketing unless it discloses:
(a) at the beginning of the communication, the identity of Pinnacle Mobile or other person on whose behalf it is made and the precise purpose of the communication;
(b) during the communication, the full price of any product or service that is the subject of the communication; and
(c) that the person receiving the communication will have an absolute right to cancel the agreement for purchase, lease or other supply of any product or service within seven (7) days of the communication, by calling a specific telephone number (without any charge, and that Pinnacle Mobile shall specifically identify during the communication) unless the product or service has by that time been supplied to and used by the person receiving the communication.
7.2. Pinnacle Mobile shall also conduct telemarketing in accordance with any “call” or “do not call” preferences recorded by the Customer, at the time of entering into a contract for services or after, and in accordance with any other rules or guidelines issued by the Commission or any other competent authority.
- Charitable promotions
8.1. Any promotional material for charitable and/or fundraising promotions must make it clear that network operator fees and administration fees shall be deducted from amounts paid.
8.2. Promotional material must specify the identity of the beneficiary.
8.3. Promotional material must make clear any restrictions or conditions attached to the contribution to be made to the beneficiary.
9. Commercial Communications
9.1. Identification of spam
9.1.1. Any commercial message is considered unsolicited (and hence spam) unless:
(i) The recipient has requested the message;
(ii) The message recipient has a direct and recent (within the last six months) prior commercial relationship with the message originator and would reasonably expect to receive marketing communications from the originator; or
(iii) The organization supplying the originator with the recipient’s contact information has the recipient’s explicit consent to do so.
9.2. Prevention of spam
9.2.1. Pinnacle Mobile does not send or promote the sending of spam and will take reasonable measures to ensure that their facilities are not used, by others for this purpose.
PART IV—CONSUMER BILLING, CHARGING, COLLECTION AND CREDIT PRACTICES
- Consumer Billing Information
10.1.1. All services are paid for via credit available on the subscribers’ phone.
- Once service is requested for, the money is deducted from the balance of the customer’s account.
- Unless otherwise promoted or advertised, we shall normally bill you upfront (in advance) for any charges for the duration of the service.
10.1.2. Pinnacle Mobile shall at all times endeavour to—
(a) ensure that billing is accurate and timely ;
(b) ensure that billing accuracy is verifiable ;
(c) ensure that sufficient information shall be readily available to the Customer for verification of the bill without any charge;
(d) ensure that upon a bona fide request from a Customer, Pinnacle Mobile shall inform or provide the Customer with timely, accurate and current information about its billing terms and conditions and options relevant to that Customer;
(e) retain records of a Customer’s bill and related charges for a minimum period of twelve (12) months; and
(f) in interpreting the obligations described in this section, references to “billing” or “bill” include Pinnacle Mobile’s systems for recording and processing any prepaid transactions, including the debiting of call charges against prepaid card balances.
10.1.3. Pinnacle Mobile shall ensure that, at a minimum, the following information is included in any bills issued by it or on its behalf :
(a) a description of the charges (and credits) for which the Customer is billed ;
(b) the total amount billed, applicable credits, payments or discounts
(c) the type of service for which the customer is billed
10.1.4. Pinnacle Mobile shall ensure that Customers have access to itemized details of all charges, either on the bill or on a separate statement provided by Pinnacle Mobile upon request.
10.1.5. Pinnacle Mobile shall not charge Customers for bills or billing related information, except where the Customer requests information not required to be provided under
this Code such as requests for billing details more than one (1) year old. Pinnacle Mobile shall inform Customers of any applicable charge resulting from their billing requests, and shall obtain the consent of the Customer to any charge before it is imposed.
10.2 . Timing for Issuance of Bill
10.2.1. Pinnacle Mobile shall process and issue bills within 30 days of the closure of each billing period. A bill shall include all charges incurred during the billing period except where :
(a) there exists a separate agreement with the Customer to the contrary ; or
(b) there is a delay as a result of the inclusion by Pinnacle of information from other suppliers or service providers in the bill ; or
(c) there is a delay as a result of a change initiated by the Customer, such as where the Customer has requested a different billing frequency or billing period ;or
(d) there is a delay as a result of the suspension of charges that are in dispute ;or
(e) there has occurred a billing system or processing problem, in which case the problem shall be rectified and bills issued without undue delay and in accordance with any time periods identified by the Commission ; or
(f) billing is delayed by circumstances beyond the reasonable control of Pinnacle Mobile, such as an event of force majeure.
10.2.2. Pinnacle Mobile shall ensure that Customers are able to verify their bill payment by acknowledgment of payment on the next bill issued, telephone confirmation by calling a specified number, or such other appropriate and accessible methods as may be made available by Pinnacle Mobile.
10.2.3. Pinnacle Mobile 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).
10.2.4. Where a Customer has not paid Pinnacle Mobile all or part of a bill for services provided by Pinnacle Mobile, any measures taken by Pinnacle Mobile to effect payment or disconnection shall—
(a) be proportionate and not unduly discriminatory ; and
(b) be accompanied by appropriate warning to the Customer in advance of any resulting service interruption or disconnection ; and
(c) confine any service interruption or disconnection to the service(s) concerned, as far as technically feasible.
- COMPLAINTS PROCEDURES & HANDLING
All complaints by customers will first be lodged and dealt with Pinnacle Mobile Limited in accordance with Clause 11 of this Code. Where a customer lodges a complaint directly with the Commission and does not contact us before lodging the complaint with the Commission, the Commission will forward the complaint to Pinnacle Mobile for resolution in accordance with our complaint handling process detailed in this Code of Practice.
11.1. Lodging of complaints
11.1.1 Customers have the right to lodge a complaint against any member of Pinnacle Mobile that has acted contrary to the Code of Practice or about any service that is not in line with the provision of the code. If you are unhappy with any of our services please contact us and let us know. It is through your feedback that we are able to review and improve the overall service we provide. If you have any complaint our formal internal complaints procedure is outlined below. We are fully committed to addressing all complaints, fully and fairly, and in a reasonable time frame. We do try and resolve complaints by telephone, however, should you wish to receive a response in writing kindly let us know and we shall duly send you a written resolution to your complaint.
11.1.2 Any complaint must be lodged using the contact information published on the Pinnacle Mobile website located at https://www.facebook.com/pinnaclemobile. Pinnacle Mobile operates a customer service desk which is reachable during working hours (9:00am – 5:00pm) via telephone and outside working hours via e-mail. All Pinnacle Mobile subscribers can contact the help desk via telephone; 08170149213 or send to firstname.lastname@example.org. Whenever a complaint is lodge, the customer should make available the user name, mobile number, the service subscribed to and a summary of the complaint. This information will assist us in resolving your complaints as quickly as possible.
11.2. Information to Customers
11.2.1. Pinnacle Mobile shall provide easily understood information about their complaint processes in various media and formats, including as specifically directed by the Commission from time to time.
11.2.2. Pinnacle Mobile shall ensure that Customers can easily identify how a complaint may be lodged, either at Pinnacle Mobile premises or using identified forms of telecommunications.
11.2.3. Information on the complaints handling processes shall contain information—
(a) to Customers about their right to complain ;
(b) on how Pinnacle Mobile can be contacted in order to make a complaint ; and
(c) on the types of supporting information including, documents the complainant needs to furnish when making a complaint.
11.2.4. All complaints will be recorded by Pinnacle Mobile, and processed in accordance with identified practices and procedures.
- Special Needs
12.1. Pinnacle Mobile is encouraged to make adequate provision to ensure that people with physical disabilities or other special needs are able to access their complaint handling processes, including ensuring that Customers can be easily represented by their authorised representatives in order to make a complaint.
12.2. In cases where customers specifically request assistance in lodging complaints, Pinnacle Mobile is encouraged to provide reasonable assistance.
- Complaint Processes
13.1. Written complaints shall be acknowledged by Pinnacle Mobile and acted on within any timeframes set out in the Commission’s Quality of Service Regulations (or as otherwise directed by the Commission from time to time). Pinnacle Mobile can acknowledge and otherwise initially respond to a complaint either verbally or in writing, but should make reasonable efforts to make the initial response in the manner requested by the complainant.
13.2. Non-written complaints shall be taken as acknowledged by Pinnacle Mobile at the time the complaint was communicated to Pinnacle Mobile.
13.3. Where possible, Customers shall be advised when they make a complaint of the expected actions and timing for investigating and resolving the complaints. In the event that Pinnacle Mobile regards the complaint as frivolous or vexatious, the Customer shall be informed accordingly and if dissatisfied the Customer shall have the further recourse described below. In any event, no Customer complaint shall remain unresolved for more than three (3) months.
13.4. Pinnacle Mobile shall implement processes to provide Customers with sufficient information and the means to inquire on the progress of complaints. Such processes may include complaint reference numbers or other identifiers in order to facilitate timely and accurate responses to subsequent enquiries by Customers.
13.5. Customers shall be advised of the outcome of the investigation of their complaint, and any resulting decision by Pinnacle Mobile.
13.6. Where a Customer is not satisfied with a decision reached pursuant to a complaint, Pinnacle Mobile shall give the Customer the option of pursuing an identified escalation process by which the decision may be examined by a suitably qualified person in Pinnacle Mobile organization. Where the Customer has already been provided with the benefit of Pinnacle Mobile escalation process(es) and where there are no further escalation processes, Pinnacle Mobile shall inform the Customer accordingly.
13.7. In the event that a complaint has not been resolved to the Customer’s satisfaction, including as a result of any escalation process, within sixty (60) days of being communicated to Pinnacle Mobile, Pinnacle Mobile shall inform the Customer that he or she may refer the complaint to the Commission.
13.8. Failure to deal with Customer complaints, and any related service failures, shall also be subject to the requirements of the Quality of Service Regulations, including
payment of any specific service credits or rebates established pursuant to these regulations.
14.1. Complaint handling processes shall be provided free of charge. However, a Pinnacle Mobile 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 to Pinnacle Mobile. Any such charges shall be identified and agreed to by the Customer before being incurred.
- Further Recourse
15.1. Pinnacle Mobile shall advise Customers that, in the event they remain dissatisfied with the outcome of a complaint they may refer the complaint to identified persons
or departments, within the Commission.
15.2. For disputes that remain unresolved by other means, the Commission will apply the processes set out in its Dispute Resolution Guidelines.
- Action on Disputed Charges
16.1. Pinnacle Mobile shall avoid imposing any disconnection or credit management action regarding any service to which a complaint or billing dispute relates while the complaint or dispute is being investigated. Pinnacle Mobile shall inform the Customer that, while the complaint or dispute, is being investigated, the Customer is obliged to make payment of any outstanding amounts other than the amount that is specifically in dispute.
16.2. Where Pinnacle Mobile intends to take disconnection or credit management action against a Customer regarding any amount that has been the subject of a complaint or dispute, Pinnacle Mobile will specifically notify the Customer before taking the intended action.
- Internal Data and Collection Analysis of Complaints and Outcomes
17.1. Pinnacle Mobile shall have appropriate recording systems for complaints and their outcomes. Such tracking is also needed to meet the requirements of the quantity of Service Regulations.
17.2. Complaints tracking data shall be categorized and analyzed by the Licensee from time to time to allow for the identification of recurring problems, Licensees shall inform the Customer that a record of their complaints is being kept, and if requested by the Customer shall describe the complaints, tracking system used by the Licensee.
- Changes to Complaints Handling Processes
18.1. Pinnacle Mobile shall update any information regarding their complaint handling and tracking processes as appropriate, including information provided to Customers or the Commission.
- Retention of Records
19.1. Information collected and recorded as part of the Licensee’s complaint handling processes shall be retained by Licensees for at least twelve (12) months following resolution of a complaint.
- OPT -IN AND OPT- OUT OPTION
All our services for Value added services has available the opt-in and Opt-out option for our all customers. Customers may decided to opt- in if they are interested in any of our services and can also chose to easily disengage whenever they have the need to do so by choosing our opt-in or opt-out option.
For example for our “Word Brain Teaser Puzzle game”, When you SMS “WORD” to 20231, the response and welcome message would be “Thank you for subscribing to the Brain Teaser game”. Subscription is N50/month. You will be sent 1 new scrambled word/day for 30days. Send answers to 20231. All texts charged N10 per text. Reply “STOP” to Opt out. For example, when you unscramble FEREERE you get REFEREE. Send your answers to 20231.
When you sms “STOP” to 20231 you will get the following response. “You have successfully opted out of word Brain Teaser Game. Reply WORD to 35230 to renew your subscription for the BRAIN TEASER GAME.