Privacy Policy

1. Information We Collect

We collect and process the following types of information:

Personal Information You Provide

When you register as a member or use our services, you provide:

• Identity Information: Full name, date of birth, gender, nationality, photograph
• Contact Details: Phone number, email address, residential address
• Identification Documents: Bank Verification Number (BVN), National ID Number (NIN), driver's license, voter's card, international passport, or other government issued ID
• Financial Information: Account details, transaction history, income information, employment details
• Biometric Data: Facial recognition data for identity verification during account opening
• Business Information: For business accounts, we collect business name, registration details, nature of business, and business address

Information We Collect Automatically

When you use our services, we automatically collect:

• Device Information: IP address, device type, operating system, browser type, mobile network information
• Usage Data: Pages visited, features used, transaction patterns, time and date of visits
• Location Data: Approximate location based on IP address, or precise location with your consent when using our mobile app
• Cookies: We use cookies to enhance your experience on our website and mobile app

Information from Third Parties

We may receive information about you from credit bureaus, identity verification services, other financial institutions for transaction processing, and regulatory authorities when required by law.

2. How We Use Your Information

We process your personal data for the following purposes:

To Provide Our Services

• Open and manage your account
• Process deposits, withdrawals, transfers, and payments
• Provide USSD services
• Process loan applications and manage credit facilities
• Administer savings and investment schemes
• Send transaction confirmations and account alerts

To Comply with Legal Obligations

• Verify your identity (Know Your Customer requirements)
• Prevent and detect fraud, money laundering, and financial crimes
• Comply with anti-money laundering and counter-terrorism financing laws
• Report to regulatory authorities as required by law
• Maintain records for audit and regulatory purposes
• Respond to court orders and law enforcement requests

To Improve Our Services

• Analyze usage patterns and member behavior to improve our products
• Conduct research and develop new financial products
• Personalize your experience
• Send you updates about new products and services (you can opt out anytime)

To Protect You and Our Cooperative

• Monitor and prevent fraudulent transactions
• Secure your account and protect against unauthorized access
• Resolve disputes and investigate complaints
• Enforce our terms and conditions

3. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your information with:

Regulatory and Law Enforcement Authorities

We share information when legally required with regulatory bodies, tax authorities, law enforcement agencies, and courts in response to legal processes.

Service Providers

We work with payment processors, card networks, IT service providers, identity verification services, SMS and email providers, and other trusted partners. These third parties are contractually obligated to protect your data and use it only for the purposes we specify.

Other Financial Institutions

When you initiate transfers to or from accounts at other institutions, we share necessary information for transaction processing and settlement.

Credit Bureaus

We may share information to assess your creditworthiness for loan applications and report loan repayment history as required by regulations.

4. Data Security

We take the security of your personal data seriously and have implemented robust measures to protect it:

• Encryption: All sensitive data is encrypted using industry standard encryption protocols
• Secure Servers: Data is stored on secure servers with restricted access
• Access Controls: Only authorized personnel with legitimate business needs can access your data
• Multi-Factor Authentication: Additional security layers for account access
• Regular Security Audits: We conduct periodic security assessments and vulnerability testing
• Employee Training: All staff receive training on data protection and confidentiality

Despite our best efforts, no system is completely secure. If we become aware of a data breach, we will notify you and the relevant authorities as required by law.

5. Data Retention

We retain your personal data for as long as necessary to provide services to you, comply with legal and regulatory obligations (we maintain member records for at least 5 years after account closure), resolve disputes, enforce our agreements, and prevent fraud.

After the retention period expires, we will securely delete or anonymize your data.

6. Your Rights

Under the Nigeria Data Protection Act, 2023, you have the following rights:

• Right to Access: You can request a copy of the personal data we hold about you
• Right to Rectification: You can request correction of inaccurate or incomplete data
• Right to Erasure: You can request deletion of your data (subject to legal retention requirements)
• Right to Object: You can object to certain types of processing, such as marketing communications
• Right to Restrict Processing: You can request that we limit how we use your data in certain circumstances
• Right to Data Portability: You can request a copy of your data in a structured, machine readable format
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time

To exercise any of these rights, please contact us using the details provided below.

7. Cookies and Tracking Technologies

Our website and mobile app use cookies and similar technologies to remember your preferences, analyze website traffic, improve functionality, and provide personalized content. You can control cookie settings through your browser, but disabling cookies may limit your ability to use certain features.

8. International Data Transfers

While we primarily operate in Nigeria, some of our service providers may be located outside Nigeria. When we transfer your data internationally, we ensure the recipient country has adequate data protection laws or appropriate contractual safeguards are in place to protect your data.

9. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately so we can delete it.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. When we make significant changes, we will post the updated policy on our website with a new "Last Updated" date, notify you via email or SMS, and display a notice on our mobile app.

We encourage you to review this policy periodically to stay informed about how we protect your information.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

12. Complaints

If you believe we have not handled your personal data in accordance with this Policy or applicable data protection laws, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

You may also contact us directly at hello@appfocusng.com to resolve any concerns before escalating to the regulatory authority.