Nigeria Privacy Notice

Last updated November 25, 2025

If you are located in Nigeria, and access our website, subscribe for Starlink services in your personal capacity, use Starlink services as an authorized user of an organization that subscribes for Starlink services, or interact with Starlink in Nigeria in any manner, this Nigeria Privacy Notice (the “Notice”) applies to you.

This Notice should be read in conjunction with the Global Privacy Policy.

1. WHO IS THE DATA CONTROLLER?

   Space Exploration Technologies Corp. with its registered office address at 1 Rocket Road, Hawthorne, US-CA, 90250, US and Starlink Internet Services Nigeria Limited with its registered office address at Mulliner Towers 39 Alfred Rewane Road, Ikoyi, Lagos State (together “Starlink”) is the controller and responsible for your personal data. References to “we”, or “us” in this Notice is a reference to Starlink.

2. WHAT ARE OUR LEGAL BASES FOR PROCESSING PERSONAL DATA?

   We rely on the following legal bases to process your personal data, as appropriate:

   • Your consent (“Consent Legal Basis”);
   • Necessary for us to perform a contract with you or take steps at your request prior to entering into a contract (“Contract Performance Legal Basis”);
   • Necessary for us to comply with an applicable legal obligation (“Legal Obligations Legal Basis”); or
   • Necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests (“Legitimate Interest Legal Basis”).

   More information is provided below. Please contact us if you need details.

   Purpose of Use or Disclosure	Legal Basis
   To manage our relationship with customers, such as communicating with them about our goods and services, providing customer service, and notifying them of changes to our terms or privacy policy	If we are legally obligated to respond to your request or inquiry, Legal Obligations Legal Basis. In all other cases, Legitimate Interest Legal Basis, including to maintain the quality of and keep our records updated, and understand how customers use our website so that we can improve them for you and others.
   To process and deliver customer orders, and manage payments, fees and charges	Contract Performance Legal Basis based on our Terms of Service, Terms of Sale or other applicable contract. If the processing of your personal data is necessary for us to collect amounts owed to us, Legitimate Interest Legal Basis based on this legitimate interest.
   To administer and protect our business and services, including troubleshooting, and performing data analysis, testing, system maintenance, support, reporting and hosting of data	If the processing is necessary to comply with an applicable contractual obligation with you, Contract Performance Legal Basis per the applicable contract. If the processing is necessary to comply with an applicable legal obligation, such as under data security laws, Legal Obligations Legal Basis. In all other cases, Legitimate Interest Legal Basis, including as necessary to run our business, provide administration and IT services, maintain network security, and prevent fraud.
   To understand what may be of interest to a customer, deliver relevant news, offers and other content to a customer, and measure or understand the effectiveness of the content, in accordance with applicable laws	We process your personal data and contact you for direct marketing purposes on the Consent Legal Basis as required by applicable law. In all other cases, Legitimate Interests Legal Basis as necessary to understand how customers use our products and services, to develop and improve them for you and others, to remain a competitive business, and to inform our marketing strategy.
   To use data analytics to debug, optimize, and improve our products and services, marketing, customer relationships and experiences	Legitimate Interests Legal Basis as necessary to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy.
   To detect, prevent, or otherwise address fraud, security or technical issues, including by monitoring and enforcing compliance with our terms of use, appropriate use policies, and privacy policies. To comply with legal obligations that apply to us, monitor and ensure compliance with our terms, and defend our legal interests in the event of a potential dispute	If the processing is necessary to comply with an applicable contractual obligation with you, Contract Performance Legal Basis per the applicable contract. If necessary to comply with applicable laws, Legal Obligations Legal Basis per applicable laws. In all other applicable cases, Legitimate Interest Legal Basis to prevent fraud, danger or other unlawful conduct, and to defend our legitimate legal interests.
   Disclose your personal data to our service providers (i.e., processors) as necessary to achieve the above purposes	The lawful bases listed above apply to any disclosure necessary to further the corresponding purpose.
   Disclose your personal data to a prospective or actual purchaser or seller in the context of a merger, acquisition or other reorganization or sale of our business or assets.	If the confidential processing of your personal data is necessary for us to evaluate or execute such a transaction while protecting our trade secrets or sensitive business information and your privacy interests to do not override such interests, Legitimate Interest Legal Basis based on the pursuit of such legitimate interests. Otherwise, we will obtain your consent and rely on the Consent Legal Basis.
   Disclose your personal data to courts, law enforcement or regulatory authorities as permitted or required by applicable law.	If necessary to comply with applicable laws, Legal Obligations Legal Basis per applicable laws. In all other applicable cases, Legitimate Interest Legal Basis to prevent fraud, danger or other unlawful conduct, and to defend our legitimate legal interests.

3. INTERNATIONAL DATA PROCESSING

   We may process your personal data outside Nigeria in a jurisdiction which may not have similar data protection law or adequacy decision for the protection of your personal data. In these instances and given the risk which may be caused by the absence of this adequate decision, we will rely on other reasonable means to ensure that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

   Where we process your data outside Nigeria, we would be doing so where you have given us your consent, or for the performance of the contract between us or for the purpose of entering into an agreement with you, or such any other legal basis permitted under the Nigerian law.

4. HOW LONG DO WE KEEP PERSONAL DATA?

   We will only keep personal data for as long as reasonably necessary to fulfil the purposes we collected it for; and may not keep personal data for more than 6 months after the original purpose for processing such data has been accomplished. We will, however, keep your personal data for a longer period to comply with our legal obligations or in the defence of a legal claim or due diligence.

   Where we share your personal data with third parties, we only share personal data to the extent that it is adequate, relevant, and limited to the minimum necessary for the purpose for which such personal data is to be processed. Similarly, we do not share your personal data with such third parties for longer than is necessary to achieve the purpose for which the data is processed.

5. YOUR RIGHTS

   Regarding your personal data, you may have the right to:

   • Be informed on how we process your personal data (which we have satisfied through the Global Privacy Policy and this Notice)
   • Request access (commonly known as a "data subject access request") - enables you to receive a copy of the personal data we hold about you and information about how it is processed.
   • Request correction - enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
   • Request erasure - enables you to ask us to delete or remove personal data where:
     • there is no lawful reason for us continuing to store or process it;
     • where you have successfully exercised your right to object to processing (see below),
     • where we may have processed your information accidentally;
     • where you have withdrawn your consent to the processing of your personal data;
     • where we process your personal data for direct marketing purpose and you successfully object to such processing; and
     • we have no other legal basis to process such data, or where we are required to erase your personal data to comply with local law.

   Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

   • Object to processing - where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
   • Object at any time to the processing of your personal data for direct marketing purposes.
   • Request restriction of processing - enables you to ask us to suspend the processing of your personal data, (i) pending the resolution of a request; (ii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iii) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
   • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
   • Right not to be subject to decisions solely based on automated processing including profiling where such decisions may produce legal or other significant effects on you. As such, where we make decision based solely on automated processing, you have the right to obtain human intervention from us, express your point of view on such decisions, and contest such decisions. This right will not apply where the legal basis for processing the personal data is contract, legal obligation or consent.

6. COMPLAINTS AND REDRESS

   We take your privacy seriously and so should you have any privacy related issues in respect of our data processing activities, we appreciate the chance to deal with your concerns before you take other legal steps available to you.

   To exercise these rights, please contact us using the contact details below. Upon receipt of your complaint or a request to exercise your right, we aim to resolve your issue as required by law, or otherwise within a reasonable timeframe, taking into account the urgency of the issue and your rights and interests. If we require more time to process your request, we will inform you of the reason and extension period in writing. Where you are not satisfied with the resolution of your request, you might have the right to appeal our decision. If applicable, our written response to your request will include information about any right to appeal.

   Although we urge you to contact us first to resolve your issue, you always have the right to lodge a complaint with the Nigeria Data Protection Commission.

7. CONTACT US

   Should you have any concern in relation to our data protection and privacy practices, contact us at privacy@spacex.com.