Privacy Policy

We understand that the information you provide us is very important and valuable. We will like to therefore explain how we collect, share and use your information.

1.COLLECTING AND STORING YOUR INFORMATION

We collect and store your information:

  • when you interact with us
  • when you visit our websites or use our products, services and mobile apps
  • from other people and companies

We store your information in physical or electronic form on our systems, our service providers’ systems or a third-party cloud locally or overseas.

We comply with the laws of Nigeria on privacy.

2.USE OF YOUR INFORMATION

We use your information:

  • to provide products and services to you
  • to market products or services to you if you’ve given us your consent to do so
  • to comply with laws, regulations and requirements, including our internal policies
  • to help us to prevent financial crimes
  • to improve our products, services and marketing
  • for the other purposes set out in section A.

3.THOSE WE SHARE YOUR INFORMATION WITH

We use your information:

  • with other companies and third parties who help us to provide services to you or who act for us
  • with third parties who you consent to us sharing your information with
  • with local or overseas law enforcement agencies, industry bodies, regulators or authorities
  • with the other third parties set out in section C.

We may share your information locally or overseas.

4.Accessing your information

You can request access to the information we store about you, we may charge a fee for this. You can also ask us to correct or update your information.

You have the option of choosing your marketing preferences. You can contact us at any time if you don’t want us to send direct marketing to you via certain channels, such as email or post.

5.Your information may be used to

  • assess you for products and services and enable us to provide and operate them
  • conduct verification or credit checks and reviews on you, obtain or provide credit references or detect fraudulent applications
  • manage our business, including our human resources, credit and other risk management functions and to comply with our internal policies
  • design and improve our products, services and marketing
  • provide you with marketing information as described below
  • provide personalized advertising (including by aggregating your information with information of others)
  • exercise our rights under contracts with you, including collecting any amounts due from you
  • comply with compulsory or voluntary requirements that we have such as legal, tax, regulatory, sanctions or market requirements in Nigeria and overseas
  • comply with requests made by different bodies or authorities such as legal, regulatory, law enforcement, government and tax authorities in Nigeria and overseas. Sometimes we may have to comply with such requests and other times we may choose to voluntarily comply
  • comply with our or company’s policies, procedures and other commitments in the detection, investigation and prevention of financial and other crimes. This may involve sharing your information in Nigeria and overseas. This is important in our wider fight against these crimes
  • allow any company that we transfer our business or assets to, to evaluate our business and use your information after any transfer
  • any other uses for which you have given consent
  • any other purpose relating to any of the purposes above.

This Privacy Policy will apply for as long as we store your information. We’ll review this Privacy Policy once a year and may make changes. We’ll publish a copy of the latest Privacy Policy on our website and send you a copy on request.

6.We may collect

  • information (including sensitive information) that you give to us such as your contact and identification details, tax file number or information about your ethnicity or origin
  • biometric information such as your facial recognition information
  • your geographic information and location information based on your mobile or other electronic device
  • information required under law.

If you don’t give us information then we may be unable to provide products or services.

We may also collect information about you from third parties such as

  • people who act for you or who you give consent to transfer information to us
  • publicly available sources or agencies that collect information which they use to create statistics or to verify your identity
  • credit reference, debt collection, fraud prevention and government agencies
  • those you deal with through our services.

We may generate information about you

  • by combining information that we have collected about you and based on the analysis of your interactions with us through the use of cookies and similar technology when you access our website or apps. See our cookies policy on www.credpal.com for more details.

7.We may collect

We may transfer and store your information overseas. Where those countries don’t have the same level of protection for personal information, we’ll take reasonable steps to ensure overseas recipients provide the same level of protection.

8.Protecting your stored information

  • While we store it, your information is protected by physical, electronic and procedural safeguards and governed by the laws of Nigeria and the Nigerian Privacy Principles.
  • Our third party service providers that receive your information are required to comply with strict measures to protect your information.
  • If you provide information about others
  • If you provide information to us about another person (such as a joint account holder, trustee, beneficiary or guarantor) you must make sure they know you have done this, and agree to us
  • processing their information as set out in this Privacy Policy. You also need to tell them how to find a copy of this Privacy Policy.

9.We share your information with

  • third parties who provide services to us or who you have consented to us sharing your information with
  • other third parties we work with or parties we need to share with for the purpose of acting on your instructions
  • any bodies or partnerships between law enforcement and the financial sector or authorities, such as legal, regulatory, law enforcement, government and tax authorities in Nigeria or overseas or anyone acting for them
  • any person who you hold a joint account with, people who can give instructions for you and anyone who may give security for your loans
  • any third party who we may transfer our business or assets to
  • partners and providers of reward, co-branding or loyalty programs, charities or non-profit organisations
  • social media advertising partners (who can check if you hold an account with them for advertising purposes and the partner may then use your information to send our adverts to you and advertise to people who have a similar profile to you)
  • We may share your anonymised information with other parties not listed above. If we do this you won’t be identifiable from this information.

10.Direct Marketing

This is when we use your personal information to send you details about products, services and offers such as financial, insurance or related products and services provided by us or our co-branding partners, rewards, loyalty privileges or charities. We’ll only do this where you’ve consented (including your indication of no objection to us).

We may use your contact details and information such as your demographic information, products and services that you are interested in, transaction behaviour, portfolio information, location information, social media information, analytics and formation from third parties when we market you.

You can tell us anytime if you don’t want to receive marketing from us by clicking our “unsubscribe” links in our emails, contacting us (it may take a short time to update our records to reflect any change), or updating your preferences on social media platforms.

We’ll need to get your separate consent to share your information with others for them to market their products and services to you.

Your rights

You can request access to your information, correct information that we hold about you and give feedback. We may be unable to provide you with access to some information — if so, we’ll explain why not unless it’s not lawful to tell you. You can also ask us to explain our data policies and practices.

Other information

We collect the following information because we are required or authorised by or under the Nigerian law:

  • your identification information under the Central Bank of Nigeria (Anti-Money Laundering/Combating the Financing of Terrorism for Banks and Other Financial Institutions in Nigeria) Regulation 2013 and The Nigeria Data Protection Regulation (NDPR)
  • your credit or financial information under the Central Bank of Nigeria Act 2007 (CBN)

We may ask a credit reporting body to assist in verifying your identity by providing us with an assessment of whether the information we hold about you matches their records. The credit reporting body may use this information and information held by the body of other individuals for the purpose of preparing and providing this assessment to us.

The Nigeria Data Protection Regulation (NDPR) contains certain exemptions in relation to certain acts undertaken in relation to employee records and related bodies corporate. Where appropriate we make use of relevant exemptions in the Act.

This Privacy Policy applies to all CredPal’s product operating in Nigeria

Making a Complaint

If you wish to make a complaint about the way we have handled your personal information, you can contact us via email at cardservices@credpal.com

We will attempt to respond to any complaints, access or correction requests as soon as possible, and no later than 30 days once we’ve verified your identity. However, where a matter is complex, we may need to ask you for an extension to this period and give you the reasons why we need to have the period extended. If you do not consent to the extension sought by us, we may not be able to resolve your complaint, access or correction request.