We collect information necessary to provide our services, verify your identity (as required by Nigerian regulations), prevent fraud, and improve your experience:

1.1 Personal Information You Provide:

1.2 Information Collected Automatically:

1.3 Device Permissions

1.4 Data Security and Compliance

We use the information we collect for the following purposes, based on legitimate business interests, contractual necessity, legal compliance, and with your consent where required:

2.1 To provide and manage the App's services: Process airtime/data purchases, facilitate loan applications, disbursements, repayments, and collections.

2.2 To verify your identity and comply with KYC (Know Your Customer) and AML (Anti-Money Laundering) regulations mandated by the Central Bank of Nigeria (CBN) and NDIC.

2.3 To assess your creditworthiness for loan services, including performing credit checks with licensed Nigerian Credit Bureaus.

2.4 To prevent, detect, and investigate fraud, money laundering, terrorism financing, and other illegal activities.

2.5 To communicate with you: Send transaction confirmations, loan status updates, service announcements, security alerts, and respond to inquiries.

2.6 To personalize your experience and improve the App: Analyze usage trends, develop new features, and enhance security.

2.7 To comply with legal and regulatory obligations under Nigerian law, including the NDPA 2023, CBN Regulations, NDIC Act, and others.

2.8 For debt recovery purposes in case of loan default (using lawful means).

2.9 For direct marketing (e.g., promotional offers for airtime/data or loans) only with your explicit prior consent. You can opt-out anytime.

We process your personal information based on one or more of the following legal grounds:

3.1 Performance of a Contract: Necessary to provide the services you request (e.g., processing top-ups, executing loan agreements).

3.2 Legal Obligation: To comply with Nigerian laws and regulations (e.g., KYC, AML, CBN guidelines, tax reporting, NDPA requirements).

3.3 Legitimate Interests: To operate our business effectively and securely, prevent fraud, manage risks, improve our services, and ensure network security (balanced against your rights).

3.4 Consent: For specific purposes where we clearly ask for and obtain your explicit consent (e.g., precise location tracking if applicable, specific marketing communications). You can withdraw consent at any time.

We may share your information only as described below and with appropriate safeguards:

4.1 Service Providers: Trusted third parties who perform services on our behalf under strict contractual obligations (e.g., cloud hosting providers in secure locations, payment processors, SMS gateways, identity verification services, credit bureaus, customer support platforms). We ensure these providers comply with data protection standards.

4.2 Mobile Network Operators (MNOs): Necessary to fulfill your airtime/data top-up requests (e.g., MTN, Glo, Airtel, 9mobile).

4.3 Credit Bureaus: To report your loan repayment history (positive or negative) as required by CBN regulations and to obtain your credit report for assessment.

4.4 Regulatory & Government Authorities: When required by law, regulation, legal process, or government request (e.g., CBN, NDIC, EFCC, Police, NDPC - Nigeria Data Protection Commission).

4.5 Fraud Prevention & Security Partners: To combat fraud and enhance security.

4.6 Group Companies: If applicable, within our corporate group for internal administrative purposes under strict confidentiality.

4.7 Business Transfers: In connection with a merger, acquisition, sale of assets, or bankruptcy. You will be notified via the App and/or email of any change in ownership or control.

4.8 With Your Consent: For any other purpose disclosed to you when you provide the information or with your explicit permission.

We implement robust technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction, in line with the NDPA 2023 requirements. These include:

5.1 Encryption of sensitive data in transit (SSL/TLS) and at rest.

5.2 Secure access controls and authentication procedures.

5.3 Regular security assessments and vulnerability testing.

5.4 Employee training on data privacy and security.

5.5 Restricted access to personal information on a need-to-know basis.

However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by Nigerian law (e.g., for tax, accounting, anti-fraud purposes, credit reporting, or regulatory compliance under CBN, NDIC, or NDPA). Retention periods are based on:

6.1 The purpose for which the data was collected.

6.2 Legal, regulatory, tax, or accounting requirements (e.g., CBN requires transaction records retention for 5+ years).

6.3 Operational needs (e.g., managing loan accounts, resolving disputes).

6.4 Legitimate business interests (e.g., fraud prevention).

We securely delete or anonymize data when it is no longer needed.

The NDPA grants you certain rights regarding your personal information. You may have the right to:

7.1 Access: Request access to the personal information we hold about you.

7.2 Rectification: Request correction of inaccurate or incomplete personal information.

7.3 Erasure (Deletion): Request deletion of your personal information under certain circumstances (subject to legal retention requirements, especially for financial records).

7.4 Restriction of Processing: Request restriction of processing your information under specific conditions.

7.5 Data Portability: Request a copy of your data in a structured, commonly used, machine-readable format (where feasible).

7.6 Objection: Object to the processing of your personal information based on our legitimate interests. You have an absolute right to object to direct marketing.

7.7 Withdraw Consent: Where processing is based on consent, withdraw your consent at any time (without affecting the lawfulness of processing before withdrawal).

7.8 Lodge a Complaint: Complain to the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.

How to Exercise Your Rights: To exercise any of these rights, please contact us using the details in Section 10 below. We may need to verify your identity before fulfilling your request. We will respond within the timeframe required by the NDPA (generally one month).

Our App and services are not directed at children under the age of 18 (Minors). We do not knowingly collect personal information from children under 18. If we learn we have collected such information, we will take steps to delete it promptly. If you believe a child under 18 has provided us with personal information, please contact us.

We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. We will notify you of material changes by:

9.1 Posting the revised Privacy Policy within the App.

9.2 Sending an in-App notification or email (where appropriate).

Your continued use of the App after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

If you have any questions, concerns, requests regarding this Privacy Policy, or wish to exercise your data subject rights under the NDPA, please contact us at: