PRIVACY POLICY
Smartloans Integrated Services Limited, a company duly registered in Nigeria to carry out money lending business operating with ‘LendSafe’ mobile app is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you apply for a loan through our application (the "App").. This Privacy Policy aims to make the You (‘User’, ‘your’) understand how and why LendSafe (‘we, ‘our’,’us’) collect, store, use, process, disclose to third party and retain your data. It also explains how we secure and protect your personal information.
The collection of your personal information is necessary for the execution of the loan service agreement with us and to fulfill our business, legal, and regulatory obligations. This Privacy Policy has been formulated in accordance with the Nigeria Data Protection Regulation 2019 (NDPR) and the Nigeria Data Protection Act 2023 (NDPA). By selecting the option indicating that you have read and agreed to this Privacy Policy, you acknowledge your acceptance of the loan agreement and the Privacy Policy, thereby agreeing to be bound by the terms of both documents.
We reserve the right to amend this policy at any time, and you will be promptly notified of any changes. To stay informed about the latest updates, we recommend that you regularly visit this page.
1.AIMS OF THIS PRIVACY POLICY
The aim of this Privacy Policy is to:
- a.Clearly communicate how we collect, use, disclose, and protect personal information obtained from Users of our loan application services.
- b. Demonstrate our commitment to complying with applicable data protection laws and regulations, including the Nigeria Data Protection Regulation 2019 (NDPR) and the Nigeria Data Protection Act 2023 (NDPA).
- c. Provide transparency regarding our data handling practices to foster trust and confidence among our users.
- d.Outline the measures we take to protect the personal information of our users from unauthorized access, use, or disclosure.
Inform users of their rights regarding their personal information and how they can exercise those rights.
2.CONSENT TO OUR PRIVACY POLICY
By downloading LendSafe app or by continuing to visit our website, you affirm that you have read, understood, and accepted the terms outlined in this Privacy Policy. You further consent to the collection, use, storage, processing, and disclosure of your personal information as described herein.
By selecting the option indicating that you have read and agreed to this Privacy Policy, you acknowledge your acceptance of its terms and agree to be bound by them. Additionally, your continued use of our services constitutes acceptance of this policy.
3.INFORMATION WE REQUEST YOU TO PROVIDE
To grant your request for loan, we may request and collect the following types of information:
- a.Personal and Information:
- To process your loan application, we may collect your personal information (including your full name, date of birth, and contact details), financial information (such as income details, employment information, and bank account details), identification documents (a valid government-issued ID), and application details (the requested loan amount and the purpose of the loan).
- b.Identification Documents:
- A valid form of identification is required, such as a voter’s card, driver’s license, international passport, or national ID card/slip, for identity verification purposes.
- c.Application Information:
- Loan Amount Requested: To understand your financial needs and process your application accordingly.
- Purpose of Loan: To ensure the loan is used for the intended purpose and complies with our terms and conditions.
4.INFORMATION WE COLLECT FROM YOU THROUGH YOUR DEVICE
When you use our website or our app, you consent that we may collect by default the following information which we require for the purpose specified thereunder:
- a.SMS:
- We will access all your text messages, but we will only use your financial text messages to assess the user's risk profile for credit assessment: to determine whether the user is eligible to use products and services, to determine how much the user can borrow, to verify the user's identity, etc. The information collected will be encrypted and uploaded to our servers (https://conn.lendsafe.ng/swnt).
- b.Approximate Location:
- We collect information about your approximate location and use it to assess your credit rating. The collected information will be encrypted and uploaded to our server (https://conn.lendsafe.ng/swnt/qpm/qpmData).
- c.Calendar:
- We'll access your calendar to remind you of your payment due dates, so you can keep your payments on time and in good credit. The collected information will be encrypted and uploaded to our server (https://conn.lendsafe.ng/swnt/qpm/qpmData).
- d.Bluetooth:
- We obtain your Bluetooth permissions, which are used to detect connected devices and prevent data breaches. We only access Bluetooth permissions when you use relevant functions, and do not collect and store unnecessary personal data, ensuring your privacy and data security. The collected information will be encrypted and uploaded to our server (https://conn.lendsafe.ng/swnt/qpm/qpmData).
- e.Device Permissions:
- We will access your device permissions and collect data related to your device, such as device model, battery level, screen resolution, etc. This helps us to ensure application compatibility and optimize application performance. This allows us to bring a better experience to our users. The collected information will be encrypted and uploaded to our server (https://conn.lendsafe.ng/swnt/qpm/qpmData).
- f.Dial number:
- We will access your phone to ensure that you can inquire about your BVN by making a call.
- g.Photo Album:
- We need access to your gallery to make sure you can select images from your device to upload and send when you use the customer service feature.The collected information will be encrypted and uploaded to our server (https://conn.lendsafe.ng/swnt/qpm/qpmData).
Rest assured, we will not alter the information you provide or share it, except to assess your loan eligibility. However, we may share your information with trusted third parties for purposes such as payment processing, identity verification, and other related services.
5.INFORMATION WE RECEIVE FROM OTHER THIRD PARTY
We may receive personal information about you from third parties in the following circumstances:
- a.Credit Bureaus: We may obtain your credit history and credit score from credit reporting agencies to assess your creditworthiness and eligibility for a loan.
- b.Verification Services: We may use third-party services to verify your identity, employment, or income details, ensuring the accuracy of the information provided in your loan application.
- c.Financial Institutions: If you apply for a loan through a financial partner, we may receive information related to your banking details or transaction history necessary for processing your application.
- d.Marketing Partners: We may receive demographic or interest-based information from marketing partners to help us understand our user base better and improve our services.
- e.Public Records: We may collect information from public databases or government sources to verify your identity and ensure compliance with legal obligations.
We ensure that any third-party sources we engage with adhere to appropriate data protection standards and that any information received is used in accordance with this Privacy Policy.
6.LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
In accordance with Nigeria Data Protection Regulation (2019) and Nigeria Data Protection Act (2023) and other relevant regulations, we rely on various lawful bases to process your personal information when you use our loan app. The lawful bases for processing your data include:
- a.Consent: We may process your personal information with your explicit consent, such as when you accept our Privacy Policy or agree to receive marketing communications. You have the right to withdraw your consent at any time, and this withdrawal will not impact the legality of any processing conducted prior to your withdrawal.
- b.Contractual and Legal Obligation: We process your personal information to fulfill contractual obligations, allowing us to provide you with loan services as outlined in our loan service agreement and to manage your account. Additionally, we may process your information to comply with legal obligations, including anti-money laundering regulations, fraud prevention, and other applicable legal and regulatory requirements related to our business operations.
- c.Legitimate Interests: We process your data based on our legitimate interests, as long as these interests do not override your rights and freedoms, which include improving our services by enhancing the functionality and user experience of our app, ensuring security and preventing fraud, providing customer support to address your inquiries and issues, and sending you relevant updates and offers, provided you have not opted out of such communications.
We are committed to processing your personal information in a lawful, fair, and transparent manner. If you have any questions or concerns about the lawful basis for processing your data, please contact us using the details provided in this Privacy Policy.
7.HOW WE USE YOUR INFORMATION
We may use the information we collect about you for various purposes, including:
- a.To Provide and Manage Our Services: We use your information to process your loan applications, manage your account, and provide you with the services you request.
- b.To Improve Our Services: We analyze user feedback and usage patterns to enhance the functionality, performance, and user experience of our app and services.
- c.To Communicate with You: We use your contact information to send you updates, respond to your inquiries, provide customer support, and deliver important information related to your account or services.
- d.For Security and Fraud Prevention: We process your information to protect our services from fraud, enhance security, and ensure compliance with legal obligations.
- e.For Marketing Purposes: With your consent, we may send you promotional materials and relevant offers. You can opt out of marketing communications at any time.
- f.Comply with Legal Obligations: We may use your information as necessary to comply with applicable laws, regulations, or legal requests.
8.USER’S RIGHTS
As a user of our loan app, you have certain rights regarding your personal information under applicable data protection laws. We are committed to ensuring that you can exercise these rights effectively. The rights you have include:
- a.Right to Access: You have the right to request access to the personal information we hold about you. This includes the ability to obtain a copy of your data and information about how it is being used.
- b.Right to Rectification: If you believe that any personal information, we hold about you is incorrect or incomplete, you have the right to request that we correct or update it.
- c.Right to Erasure: Under certain circumstances, you have the right to request that we delete your personal information. This may apply if your data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent where processing is based on consent.
- d.Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal information in specific situations, such as when you contest the accuracy of the data or object to its processing.
- e.Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another data controller, where technically feasible.
- f.Right to Object to Processing of Your Data: You have the right to object to the processing of your personal information in certain circumstances, particularly where processing is based on legitimate interests or for direct marketing purposes.
- g.Right to Withdraw Consent: If we process your personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- h.Right to Complain to us: If you are not satisfied with our service or need to make clarifications, you have the right to contact us.
To exercise any of these rights, please contact us using the contact us via: service@smartloans.ng
We will respond to your request within the timeframes required by law and will provide you with the information or action requested, subject to any legal limitations.
9. INFORMATION STORAGE
We store and process your personal information on our computers, servers, and data centres both in Nigeria and internationally. If we need to transfer your data to another country, we will ensure that the destination country has adequate data protection laws in place and will seek your consent.
We take measures to protect your personal data against unauthorized access or breaches by implementing appropriate technical safeguards. These include firewalls, data encryption, physical access controls to our data centers, and access authorization controls. However, while we strive to employ the latest security measures, we cannot guarantee the complete security of your data if it is intercepted by malicious actors through means beyond our control.
10. USE OF COOKIES
Our website utilizes cookies, which are small data files stored on your computer’s hard drive that help identify your device while you browse our site. Cookies can serve various functions, including analytics to estimate user numbers on our website and application. They may also be employed for additional purposes, such as enhancing site security, informing us of necessary administrative support, and facilitating digital marketing efforts.
11.DATA RETENTION
We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and in line with our legal and regulatory obligations.
12.LINKS TO OTHER WEBSITE
Our website may contain links to third-party websites that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of these third-party sites. We encourage you to review the privacy policy of any website you visit, as we are not responsible for the information you provide to them or their use of your personal information.
Your use of any third-party websites is at your own risk, and we recommend that you read their privacy policies carefully before providing any personal information.
13.GOVERNING LAW
This Privacy Policy is made pursuant to the Nigeria Data Protection Act (2023) and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.
14.REMEDY FOR VIOLATION OF THIS PRIVACY POLICY
The remedy for any violation of this policy will depend on the nature of your grievance and may include:
- (a)conducting an investigation, either independently or in collaboration with a data protection compliance organization, to identify and address the source of your concern;
- (b)deleting your data from our database;
- (c)rectifying your data;
- Or
- (d)imposing restrictions on the further processing of your data.
15.OUR CONTACT INFORMATION
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to service@smartloans.ng
16.CHANGE TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time to reflect changes to our app, the service site, or applicable laws. The revised policy will be effective as of the published effective date. Any future changes made to this Policy will be posted on this page and, notified to you when you next start the app or log onto our service sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the app or the services. In any event, by continuing to use the app or any services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.
Last Updated October, 2024.