- A. Information we may collect from you

We may collect and process the following data about you.

Information you give us (Submitted Information):

1. Information provided by filling in forms when visiting our sites or using our App.
2. Information provided by corresponding with us, for example by email or chat.
3. Information provided by downloading or signing up on the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App's social media functions, entering a competition, promotion, or survey, or reporting a problem with the App, our Services, our App Site, or any of our Service Sites.

Information we collect about you and your Device:

1. Technical information, including the type of mobile device you use, unique device identifiers (for example, your Device's IMEI or serial number), information about the SIM card used by the Device, mobile network information, your Device's operating system, the type of browser you use, and your Device's location and time zone setting (Device Information).
2. Data from your use of any other third-party application on the Device or the Service Sites.
3. Details of your use of any of our Apps or your visits to any of our Service Sites, including, but not limited to, traffic data, location data, weblogs, and other communication data (Log Information).

We may also collect Location Information, information we receive from other sources (Third Party Information), and unique application numbers.

- B. Tracking and cookies

We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site, or Service Sites. This helps us to provide you with a good experience when you use the App or browse any of the Service Sites and also allows us to improve the App and Our Service Sites.

- C. Uses made of the information

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.

Information collected by us shall be used for the purpose of determining whether or not to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan. This information may also be used to maintain the Service, provide customer care and support, provide analysis for the improvement of the Service, notify you of changes made to the Service and detect and prevent technical issues.

Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied for a loan on any given day).

- D. Disclosure of your information

We may disclose some or all of the data we collect from you when you download or use the App to credit reference bureaus.

- E. App permissions

NOLT Finance will not access, download, or harvest your smartphone's personal contacts, private photo galleries, SMS messages, or local media storage files for the purpose of assessing your credit eligibility or conducting underwriting. All credit assessments are completed strictly using the authorized datasets disclosed in our Data Processing Agreement. To operate the App securely, we request only the following permissions.

Location

If the App requires access to your precise device location, this is handled through a separate, explicit in-app prompt. Location data is used solely to verify that transactions are initiated within permissible geographic boundaries and to prevent fraud. We will upload location data to the NOLT server with high level protection.

Device

We collect and monitor specific information about your device, including your device name, model, region and language settings, device identification code, device hardware and software information, status, usage habits, and unique device identifiers such as the IMEI and serial number. This uniquely identifies the device and ensures that unauthorised devices cannot act on your behalf, in order to prevent fraud. We will upload the collected data to the NOLT server with a high level of protection.

- F. Data storage

We store all collected information with a high level of protection, in accordance with the data protection laws of Nigeria.

How We Use Your Data

We collect certain data to be able to provide the Service to you. We also collect data for use in verifying your identity and creating credit scoring models to determine what Loans can be offered to you. We also use this data for purposes of collections and credit reporting.

- G. The data we collect

When you register for the Service, we will collect your bank number and telephone number and may also collect your name, age, email address or other contact information. With this information, we cross-check your identity with third parties including the person you have provided as your emergency contact. We will also collect data from your device for security and fraud-prevention purposes. This includes information relating to your device, such as device maker and model, operating system, installed software applications, and the unique user identifier, together with GPS location information where you have granted permission through a separate, explicit in-app prompt. We do not collect your phone-book contacts, SMS logs, photos, or other local media for credit scoring; all credit assessments are completed strictly using the authorized datasets disclosed in our Data Processing Agreement. To supplement this information, we also collect data from third parties such as credit bureaus and other financial institutions. By registering for the Service, you authorize the collection and processing of the foregoing data. We will ensure that your data is protected to a strict standard.

We may disclose your personal information to any member of our group, which means our subsidiaries, affiliates, our holding company and its subsidiaries.

We may disclose your personal information to third parties in the following circumstances:

1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
2. If NOLT or substantially all of its assets are acquired by a third party, in which case personal data held by NOLT about its customers will be one of the transferred assets.
3. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
4. In order to enforce our Terms and Conditions and other agreements, investigate potential breaches, report defaulters to any credit bureau, or publish statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

- H. Where we store your personal data

The data that we collect from you may be transferred to and stored at a destination outside your country of origin or residence (as applicable) where the data protection laws may differ from those in your jurisdiction. It may also be processed by staff operating outside your country of origin or residence (as applicable), who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests on the Service Sites. By submitting your personal data, you agree to the collection, transfer, storing or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this Policy.

- I. Security of Data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. No transfer of your data will take place to an organisation or a country unless adequate controls are in place to secure your data and other personal information.

Notwithstanding the undertaking above, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, using global best practices, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences.

If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. You are reminded to log off from your account and close the browser when finished while using a shared computer.

- J. Your Privacy Rights

You have the following privacy rights:

1. The right to rectification.
2. The rights of access, erasure, and restriction of processing.
3. The right to withdraw consent.
4. The right to lodge a complaint with a supervisory authority.

- K. Legal Age

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child or children have provided us with personal data, please contact us at customercare@noltfinance.com. If we become aware that we have collected personal data from children without verification of parental consent, we shall take steps to remove that information from our servers.

- L. Links to Other Sites

The App may provide hypertext links to other sites operated by other people. Using such a link means you are leaving the App. We take no responsibility for, and gives no warranties, endorsements, guarantees or representations in respect of, linked sites. We are not responsible for the privacy practices, nor do we accept any liability in connection with the content of, such websites or applications, which will in some cases have their own privacy policies tailored for the particular business practices in which they operate. Any concerns regarding any external link should be directed to its website or app administrator.

- M. Changes to the Policy

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the 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.

- N. Data and Account Deletion Procedure

To delete your NOLT account:

1. Log in: Access your NOLT App by logging in, or download the App again if it has been uninstalled.
2. Navigate: Go to the 'Account' section within the App.
3. Delete Account: Scroll down to find the 'Delete Account' option and tap it to initiate the deletion process.

Once you initiate the deletion request, our backend services will process your account for deletion. However, there are certain conditions under which account deletion cannot be processed:

1. Outstanding loans: If you have any outstanding loans with NOLT, you are required to settle them before your account can be deleted.
2. Account balance: If your account has any remaining balance, you must transfer it out of your account before deletion can proceed.
3. Legal or regulatory actions: If your account is involved in any ongoing legal or regulatory actions, we are obligated by law to resolve these matters before proceeding with account deletion.

Please ensure compliance with these conditions to facilitate the smooth deletion of your account.

If, however, you want to delete only part of your data, such as removing existing bank accounts, debit cards, or direct debit mandates, please log into the NOLT App, go to the appropriate sections under Account or Settings, and delete them.

Should you require additional help with deletion, please contact us via email.

- O. Contact Us

Contact us by sending an email to customercare@noltfinance.comif you have any questions about this Policy.