Last Updated: June 21, 2026

1. Corporate Identity and Scope

This Privacy Policy governs the processing of personal data by Envictus Networks Comercio e Servicos Limitada, a limited liability company incorporated under the laws of the Republic of Angola, trading as Envictus Networks Lda and Envictus Networks (collectively referred to as “the Company”, “we”, “us”, or “our”).

We operate as a licensed Fixed Wireless Access Internet Service Provider (FWA ISP) under the regulatory oversight of the Instituto Angolano das Comunicações (INACOM). We are a registered member of the African Network Information Centre (AFRINIC) holding Autonomous System Number ASN 329697, and participate actively within the AONOG and AOPF operational communities.

This policy applies to all visitors of our website, digital platforms, service subscribers, and international partners. It fulfills our notification obligations under the Angolan Data Protection Law (Lei n.º 22/11 de 17 de Junho) and aligns with the European Union General Data Protection Regulation (GDPR) to guarantee secure international data environments for our European customers and partners.

2. Lawful Grounds for Processing

We process data under strict legal parameters. We ensure that no data is collected without clear, unambiguous, and prior consent from the data subject, except when strictly necessary to fulfill our telecommunications service contract or to meet mandatory legal requirements.

• Contractual Necessity: Processing subscriber contact info, billing records, installation addresses, and signal telemetry to provision FWA internet connections.
• Consent: Collecting non-essential browser cookies or processing marketing preferences on our website.
• Legal Obligation: Maintaining transaction logs or mandatory technical data required by INACOM and Angolan telecommunications statutes.

3. Data Categories Collected and Stored

As an FWA ISP, we segment data into two strict categories to minimize security vulnerabilities:

• Administrative and Account Data: Names, physical installation coordinates, NIF (Número de Identificação Fiscal), email addresses, telephone numbers, and billing history.
• Network Traffic and Routing Logs: Technical metadata required to maintain network routing integrity under ASN 329697, including dynamic/static IP address assignments, timestamps of connections, and bandwidth usage statistics.
• Strict Exclusion: We do not intercept, inspect, or log the contents of user communications, browsing history, or application-layer data packets passing through our FWA infrastructure, except under the rigid judicial circumstances outlined in Section 6.

4. International Transfers and GDPR Alignment

To accommodate our European partners and ensure structural data parity with the GDPR, Envictus Networks implements strict security measures for cross-border data processing:

• APD Authorization: In accordance with Angolan Law 22/11, any transfer of personal data outside the national territory is subject to prior notification or authorization from the Agência de Protecção de Dados (APD).
• GDPR Protections: When handling personal data originating from EU citizens or partners, we apply the foundational principles of the GDPR, ensuring that standard contractual clauses (SCCs) are integrated with international upstream transit providers and vendors.

5. Data Subject Rights

We recognize and uphold identical rights for both domestic subscribers under Angolan law and European entities under the GDPR:

• Right of Access and Confirmation: Users can request absolute confirmation regarding whether their data is being processed, alongside copies of their recorded accounts.
• Right to Rectification: The right to immediately correct incomplete or inaccurate data entries.
• Right to Erasure (“Right to be Forgotten”): Request deletion of data when the processing contract concludes, provided retention is not mandated by INACOM or tax audit frameworks.
• Right to Object/Restrict: Users can object to specific data deployments, such as corporate marketing communications.

6. Protection Against Unlawful Government Intervention and Due Process

Envictus Networks respects national law but prioritizes the constitutional right to privacy and communication secrecy enjoyed by our users under the Constitution of the Republic of Angola. We mitigate the risks of illegal state surveillance, overreach, and unauthorized data interception through the following protocols:

• The Judicial Mandate Requirement: No subscriber data, traffic metadata, or account profiles will be disclosed to law enforcement, intelligence services, or government agencies unless presented with a valid, written, and certified judicial warrant issued by a competent court of law in Angola.
• Rejection of Informal Requests: Verbal orders, informal letters, or warrantless requests from administrative, police, or intelligence bodies without verified judicial backing will be formally rejected by our legal department.
• Due Cause Verification: Our legal team will review every court order to verify its legitimacy, specific scope, and compliance with Lei n.º 7/17 (Protecção das Redes e Sistemas Informáticos). We actively oppose overbroad “fishing expeditions.”
• Transparency and Notification: Where legally permissible and not barred by an active, judicially ordered gag decree, Envictus Networks reserves the right to notify affected subscribers if their data is requested by state entities.

7. Technical Security and ISP Integrity

Maintaining an autonomous network footprint under ASN 329697 demands robust infrastructure defense. We use enterprise-grade access control, network segregation, end-to-end encrypted databases, and strict logging protocols to prevent unauthorized access, alteration, or theft of user data. Any suspected data breach affecting subscriber data will be reported directly to the APD and affected parties within the legal timeframe.