Privacy Policy

1. INTRODUCTION

This Privacy Policy explains how AGX-COM Ltd ("we", "us", "our") handles data within the AgxLiSYS (Advanced Lawful Intercept System). This system is operated exclusively for authorized Nigerian security and law enforcement agencies in accordance with Nigerian law.

2. LEGAL BASIS

AgxLiSYS operates under the following legal frameworks:

• Nigerian Communications Act 2003 - Lawful interception requirements
• Cybercrimes (Prohibition, Prevention, etc.) Act 2015 - Digital evidence handling
• Nigeria Data Protection Regulation (NDPR) 2019 - Data protection compliance
• Evidence Act 2011 - Chain of custody requirements

3. DATA COLLECTED

3.1 User Data (Authorized Officers)

We collect the following information about system users:

• Username and authentication credentials
• Full name and agency affiliation
• Email address and phone number
• IP address and login timestamps
• All system actions and queries (audit trail)

3.2 Intercept Data (Subjects of Investigation)

Under valid court warrants, the system collects:

• Telecommunications: Voice calls, SMS messages, location data
• Social Media: WhatsApp, Telegram, TikTok, Facebook, Instagram communications
• Identity: NIN records, SIM registrations, biometric data
• Financial: BVN records, bank accounts, transaction history

3.3 System Metadata

• Warrant information and authorization details
• Target information and investigation status
• System performance and health metrics
• Security logs and access attempts

4. HOW WE USE DATA

4.1 Lawful Intercept Operations

Intercept data is used exclusively for:

• Criminal investigations authorized by court warrant
• National security operations authorized by law
• Counter-terrorism activities
• Financial crime investigations (EFCC)

4.2 System Administration

User and system data is used for:

User authentication and access control

Audit trail and compliance reporting

System security and performance monitoring

Training and quality assurance

5. DATA STORAGE & SECURITY

5.1 Storage Location

• All data stored on secure servers in Nigeria
• Cloud infrastructure: AWS (Amazon Web Services)
• Database encryption: AES-256
• Backup retention: 7 years (legal requirement)

5.2 Security Measures

• Encryption: HTTPS/TLS 1.3 for all communications
• Authentication: Strong passwords, session timeouts
• Access Control: Role-based permissions (RBAC)
• Audit Logging: Complete activity trail
• Network Security: VPN for operator connections
• Physical Security: AWS data center protections

6. DATA SHARING

6.1 Authorized Agencies

Data is shared only with:

• The requesting agency (subject to warrant scope)
• Court-authorized reviewing authorities
• ONSA for national security coordination (as authorized)
• NCC for regulatory oversight

6.2 Network Operators

Technical data sharing with telecom operators:

• Warrant validation requests
• Target activation/deactivation notifications
• Technical integration communications

6.3 Third Parties

We do NOT share data with:

• Foreign governments (except via MLAT)
• Private companies (except authorized service providers under NDA)
• Media or public disclosure

7. DATA RETENTION

• Active Investigations: Retained until case closure + 7 years
• Audit Logs: Retained for 10 years (compliance)
• User Accounts: Retained while active + 2 years after deactivation
• System Metadata: Retained for 5 years

8. USER RIGHTS

8.1 Authorized Users

System users have the right to:

• Access their own account information
• Request correction of inaccurate personal data
• View their audit trail
• Report security concerns

8.2 Subjects of Investigation

Individuals under investigation:

• Have NO right to access intercept data (would compromise investigations)
• May request information post-investigation (subject to court approval)
• Are protected by warrant requirements and judicial oversight

9. COOKIES & TRACKING

9.1 Essential Cookies

We use cookies for:

• Session Management: Keep you logged in (1 hour timeout)
• CSRF Protection: Prevent unauthorized actions
• Preferences: Remember interface settings

9.2 Analytics

• Prometheus/Grafana for system performance monitoring
• Internal analytics only (no third-party trackers)
• Aggregated, non-personal data

See our Cookie Policy for details.

10. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect:

• Changes in legal requirements
• New system capabilities
• Security enhancements

Users will be notified of significant changes via email and system notification.

11. CONTACT INFORMATION

Data Protection Officer:

AGX-COM Ltd
Email: privacy@agxii.com.ng
Phone: +234-907-308-8287
Address:118, Ogba Road, Ikeja, Lagos, Nigeria

Regulatory Complaints:

Nigeria Data Protection Commission (NDPC)
Website: ndpc.gov.ng

12. ACKNOWLEDGMENT

By accessing AgxLiSYS, you acknowledge that:

• You are an authorized user of this restricted system
• You understand the confidential nature of data accessed
• You agree to comply with all applicable laws and regulations
• Unauthorized access is a criminal offense under the Cybercrimes Act 2015