PrivacyPolicy
1. DEFINING
Any capitalized terms used in this Privacy Policy will have the same meanings as those ascribed to them in our Terms of Use (where applicable), unless otherwise indicated.
2. PERSONAL INFORMATION THAT WE ACQUIRE
We gather specific personal information about you. You may provide us with personal information from third parties or we may automatically collect it when you use the App. For instance, you may provide us with Personal Information when you establish an account to access the Service through the App or in other manners. There are numerous methods and justifications for which we can collect information, including those that are permissible by law.
The following information is collected each time you visit our website or use the app:
2.1 Cookies may be employed to automatically collect specific information each time you use the App or visit our website. Cookies are small program files that are stored on your mobile device or computer. In order to enhance the user interface and experience, we employ cookies to monitor user behavior. Despite the fact that the majority of mobile devices and web browsers support cookies, it is possible to modify the settings of your device or browser to either deny specific categories of cookies or to completely prevent their use. Additionally, you would always have the ability to eliminate any cookies that were previously stored by utilizing your mobile device and/or browser. Nevertheless, this can impact the functionality of our website or application.
2.2 In order to utilize the service, the user is required to provide their emergency contact list, call and SMS records, photographs, videos, or other digital assets. The technical specifications and unique identifiers of your mobile device, including the IMEI number, MAC address, and phone number, as well as the mobile network, operating system, mobile browser type, and timezone preferences, must also be provided.
2.3 When you register with us and create an account through the App, you are required to provide the following specific personal information: your name, BVN (Bank Verification Number), date of birth, gender, educational background, physical address, email address, employment information, marital status, emergency contacts, phone number, SIM card details, financial and credit information (including your Mobile Money account details, bank account details, and bank verification code (if applicable), and account ID and/or password). After completing the registration process, you will utilize these credentials to access the application.
3. THE APPLICATION OF THE PERSONAL DATA WE HAVE COLLECTED
The personal information that we have collected may be utilized for the following purposes in accordance with current legislation:
3.1 Your personal data may be utilized in the following manners:
3.1.1 identifying and registering you as a user, as well as managing or regulating your account and credit terms;
3.1.2 We reserve the right to implement or execute any necessary checks prior to registering you as a user.
3.1.3 to collect fees for the service and to disseminate the loan;
3.1.4 to conduct credit assessments and develop credit models;
3.1.5 is required to adhere to pertinent laws, regulations, and directives, including those that pertain to anti-money laundering and "know-your-customer" obligations.
3.1.6 to communicate with you and furnish you with information regarding the application;
3.1.7 to inform you of any modifications to the Service or updates to the App;
3.1.8 to address and resolve the inquiries and feedback you have submitted;
3.1.9 to enhance, test, update, and personalize the application to align with your preferences and requirements as a user;
3.1.10 To contact you by telephone using pre-recorded or auto-dialed messages, or text messages (SMS), if applicable, for the purposes specified in this Privacy Policy and the Terms of Use;
3.1.11 to gather and analyze demographic and user data, including the application's service utilization patterns and trends; and
3.1.12 to send you direct marketing communications, with a particular emphasis on information regarding special offers and promotions.
3.2 In addition, we may utilize your Personal Information for the following overarching objectives, notwithstanding our commitment to acting responsibly and utilizing no more Personal Information than is required for the specific purpose in each instance:
3.2.1 to execute pertinent business processes and operations;
3.2.2 the supervision of the application's use, as well as the administration, maintenance, and enhancement of its usability, performance, and functionality;
3.2.3 to address and resolve any issues or malfunctions related to the application's functionality;
3.2.4 generating anonymized statistical information and analytics data for the purpose of conducting research, testing, and analysis in the product development process;
3.2.5 to investigate, identify, and prevent any unlawful, dishonest, prohibited, or unauthorized activities;
3.2.6 to facilitate business asset transactions, including asset sales, mergers, and acquisitions, that involve us and/or any of our Affiliates; and
3.2.7 In addition to conducting regulatory inquiries, investigations, and directives, it is imperative that we fulfill our obligations in accordance with all relevant laws. This encompasses conducting audit assessments, due diligence, and investigations.
4. DISPLAY OF THE PERSONAL INFORMATION WE RECIEVE
4.1 We reserve the right to disclose or share your personal information with Affiliates and other parties for any of the following reasons, as well as any other reasons permitted by applicable law, such as the Nigeria Data Protection Act, 2023. However, we will always act reasonably and disclose or share no more personal information than is necessary for the specific purpose:
4.1.1 for the purposes specified in the relevant law, in accordance with its provisions (including but not limited to responding to regulatory inquiries, investigations, or directives, and adhering to statutory or regulatory filing and reporting requirements);
4.1.2 in any legal proceeding involving the Service that involves you, us, or another individual, for the purpose of that legal proceeding;
4.1.3 during the negotiation of any consolidation or restructuring, merger, transfer of company assets, financing, or acquisition of all or a portion of our business by or into another company, even if such a transaction is not ultimately executed;
4.1.4 when we disclose your Personal Information to third parties (banks, mobile network providers, collection agencies, our agents, vendors, suppliers, contractors, partners, and any other individuals who work for us, perform tasks on our behalf, or are involved in our business) in order to facilitate their engagement or our collaboration with them (as applicable). This may involve granting third parties the authority to market or sell products or services to you, as well as to research, evaluate, and create items on your behalf.
4.1.5 We will not disclose personal information to Affiliates unless it is necessary for them to assist us in the operation of our business or the provision of the App (including direct marketing if you have subscribed to our mailing list) or if they are processing data on our behalf. We are dedicated to ensuring that all of our Affiliates manage the Personal Information we provide them in accordance with this Privacy Policy and all pertinent legal requirements.
4.1.6 If we disclose usage data for the Service and the App, all information will be anonymized and aggregated.
4.1.7 If we are of the firm conviction that disclosing your personal information is essential to prevent you or others from injury, to report suspected unlawful activity, to investigate potential violations of our terms of service, or to comply with the law;
4.2 If it is not necessary, we will take all reasonable measures to eliminate any means by which the information can be individually linked to you before sharing or disclosing Personal Information to third parties.
4.3 We may disclose or distribute your personal information in addition to the terms of this privacy policy with your permission and prior notice.
5. TRANSNATIONAL TRANSFER OF PERSONAL DATA
While utilizing any of our services, your personal information may be transmitted, stored, utilized, and processed in a jurisdiction that is not your home country or the jurisdiction of the country, state, or city in which you are located ("Alternate Country"). Furthermore, information may be transmitted to the servers, service providers, and associates of Our group, as well as to businesses that are affiliated with Our group and are situated outside of your country of residence or another country.
In the event that such a situation occurs, we will guarantee that the Personal Information in question is safeguarded to the extent required by Nigerian law (and, in any case, in accordance with our obligations under this Privacy Policy).
By signing this document, you consent to the transmission of your personal information in the manner outlined below, regardless of whether the transfer occurs in your country of origin or elsewhere.
6. SECURITY OF PERSONAL DATA
Your personal data will be retained for the duration necessary to accomplish the purpose for which it was collected or for the duration permitted by applicable legislation. As soon as it is reasonable to presume that the purpose for which the Personal Information was collected is no longer being served by its retention and that it is no longer necessary for legal or business purposes, we will cease to retain the Personal Information or remove the means by which it can be traced back to you.
7. RECTIFICATION AND ACCESS TO PERSONAL INFORMATION AND UPDATES
7.1 The information provided below enables you to request access to and/or correction of your personal information that is under our control. We reserve the right to impose an administrative fee provided that the requests adhere to the pertinent legal requirements.
7.2 We reserve the right to deny requests for access to or correction of any or all of your personal information that is in our possession or control, if required or permitted by law. This may involve situations in which the Personal Information contains references to other individuals or when a request for access or correction is made for reasons that we consider to be meaningless, superfluous, or inconvenient.
8. THE LOCATION OF YOUR PERSONAL INFORMATION
8.1 Third-party service providers may process, transmit, or retain the Personal Information we collect from you. We will make every effort to guarantee that all third-party service providers adhere to the same privacy guidelines as delineated in this policy.
8.2 Our foreign employees, third-party suppliers, contractors, affiliates, and service providers may retain or process your personal information outside of your nation to the extent permitted by applicable law. In the event that this occurs, we guarantee that the pertinent Personal Information will be safeguarded to the fullest extent permitted by the laws of your country (and, in any case, in accordance with our obligations under this Privacy Policy).
9. THE SAFEGUARDING OF YOUR PERSONAL INFORMATION
Protecting the privacy of your personal information is our top priority. Your personal information will be safeguarded from unauthorized access, acquisition, use, or disclosure, as well as from inadvertent loss, deletion, or injury, to the best of our ability. Regrettably, there is no absolute assurance that any information transmitted via the Internet will be secure. We cannot ensure that any Personal Information you transmit over the Internet will remain accurate and up-to-date, or that it will not be intercepted, accessed, disclosed, altered, or destroyed by unauthorized parties, despite our best efforts to safeguard it.. We trust that you have received this. This is the result of external factors. You are responsible for safeguarding the privacy of your account information, ensuring the security of your mobile device, and preventing the leakage of passwords.
10. CHANGES TO THIS POLICY REGARDING PRIVACY
We reserve the right to periodically review and amend this Privacy Policy to ensure that it accurately reflects our current procedures and any modifications that may arise from evolving legal or regulatory requirements. We will either send you an email at the address you provided in your account or post a general notice on the App and/or Website if we decide to modify this Privacy Policy. You are aware that it is your responsibility to regularly review our Privacy Policy for the most up-to-date information regarding our data processing and security protocols. If you continue to use the App or Website, contact us, or access and use the Service after the modifications to this Privacy Policy are implemented, you will be considered to have accepted them.
11. LANGUAGE
In the event that there are any discrepancies between the English and other language variants of this privacy statement, the English version will be implemented.
12. CONSENT AND ACKNOWLEDGEMENT
12.1 By accepting the Privacy Policy, you acknowledge that you have reviewed, comprehended, and concur with all of its terms. By signing this document, you consent to the collection, use, disclosure, storage, transfer, and processing of your personal information in accordance with the terms of this privacy policy.
12.2 You represent and warrant that you have the individual's consent and hereby consent on their behalf to the collection, use, disclosure, and processing of their Personal Information by us in the event that you provide us with Personal Information about other people, such as your spouse, family, friends, or emergency contact.
12.3 Additionally, you grant us your explicit consent to contact you and your emergency contact (provided that they have granted us permission) to verify your information in the event that we are unable to contact you through alternative methods or if we have not received your loan payment.
12.4 You have the right to revoke your consent to the acquisition, use, or distribution of your personal information at any time by providing us with a reasonable written notice using the contact details provided below. Furthermore, you have the option to revoke your assent for us to send you specific communications and information by utilizing the "unsubscribe" or "opt-out" option that is outlined in our correspondence with you. After the withdrawal, you acknowledge and accept that you may be unable to use the App or specific components of the Service, contingent upon the specific circumstances and the type of consent you are withdrawing. If you revoke your consent, our contractual relationship and your account may be terminated, and all accumulated rights and obligations will be fully reserved. As soon as we receive your communication expressing your desire to revoke your consent for the acquisition, use, or disclosure of your personal data, we will inform you of the potential repercussions. Afterward, you will be afforded the opportunity to determine whether or not you wish to revoke your consent.
13. PROMOTIONAL AND MARKETING CONTENT
13.1 We may send you marketing and promotional communications via mail, phone, short message service (SMS), email, online messaging, or push notifications through the App to inform you of special offers, promotions, or events that we, our partners, sponsors, or advertisers are hosting or organizing, or to provide you with updates on our App and/or the goods and services that are available on it.
13.2 You have the option to opt out of receiving these marketing messages in the future by selecting the "unsubscribe" link in the relevant message or by contacting us using the information provided below. We would like to inform you that we may continue to send you non-promotional notifications regarding your account or the app, loan disbursement or repayment receipts, and other information, even if you elect to opt out.
14. THIRD-PARTY-MANAGED WEBSITES
14.1 External websites operated by third parties may be linked to the App and Website. We are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by these third parties, as we have no control over these websites. To ascertain the manner in which these third-party websites collect and utilize your personal information, please refer to their privacy policies and terms and conditions, respectively.
14.2 The advertisements on our app or website contain hyperlinks to the advertiser's website. Consequently, the advertiser will collect and utilize any information it acquires from your click on the link in accordance with the advertiser's privacy statement.
15. LIMITATIONS ON LIABILITY
We do not provide coverage for any indirect, incidental, consequential, exceptional, exemplary, or punitive damages that may result from the following:
15.1 The manner in which you rely on and utilize the application, or your inability to access or utilize it; or
15.2 Any interaction or transaction you engage in with any other third party, regardless of whether we have been informed of the potential for such losses.
We will not be held accountable for any delay or nonperformance that is the result of circumstances beyond our reasonable control.
16. HOW TO CONTACT US
Please e-mail our data protection officer at trustworthy@jollofcash.com with any inquiries regarding our privacy policy. You will have the capacity to access and modify your personal information.
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