Privacy Policy
This Privacy Policy document (“Privacy Policy”) is published in accordance with the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.
By visiting the NairaCupmobile and/or web application (the “App”) (collectively, the “Platform”) and availing the services provided by us (“Services”) you agree to be bound by the terms and conditions of this Privacy Policy.
By mere access to the Platform or any part thereof, you signify your assent to this Privacy Policy and consent to the processing of your personally identifiable information (Personal Information, Sensitive Personal Data or Information) to NairaCup(“we” or “our” or “us” ). This Privacy Policy is incorporated into and subject to the Terms of Use of the Platform.
For the purpose of this Privacy Policy, the users of the Services may be customer/applicant / borrower/ consumers, or any other persons using Services or accessing our Platform (“user” or “you” or “your”).
If you do not agree to this Policy or any part thereof, please do not use/ access/ download or install the Platform or any part thereof.
All below data will be uploaded to https://api.ngnairacup.com . We will delete the all these data after we have determined your risk profile.
PERSONAL INFORMATION COLLECTED
The information to which we hold the right to collect a user and or visitor for your better experience while using our service may include but not limited to:
Identification Information
We may collect personal informations from you such as your name, age, telephone number, email address , date of birth, annual income or other government-issued ID number. You may also be asked to provide identification information to confirm your identity. We may cross-check your identity with credit agency and/or third parties including your emergency contact.
SMS
We may need to collect your historical text messages to assess your ability to pay and identify credit fraud. After you agree to the authorization, we will transfer and store the data through an encrypted interface (https://api.ngnairacup.com). It is only necessary to analyze data related to financial transactions in your SMS, such as the date, sender ID, and amount of transaction, in order to assess your credit risk. We ensure that your data is not shared with any third party. If you refuse, you can still use our app normally, but your loan application may fail After permission, permissions can be stopped. If you would like to delete your data, you can contact us via email and we will delete all of your SMS data.
Call Log
When applying for a loan, we will use the call recording permission to obtain the contact phone number and call time, and verify the device by making a phone call to check the corresponding number in the call log to determine if you have received the call. It can improve the user's login experience and verify the authenticity of the user's identity. Simultaneously protecting account security and identifying fraud risks. The data will be uploaded to our server(https://api.ngnairacup.com).We will never share this data with other partners.
Contact book:
In order to find reliable references for risk analysis, we would take contact information from your device and send it to our server(https://api.ngnairacup.com). The contact information should include phone contact names, phone numbers, and other information included in the contact book for our risk control. It will send the data to your phone contact lists periodically while using this app.Your information will not be shared to the third party without your permission. Your information will be collected when you agree.
Device
We may collect your device information including your device name, the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system, language settings, device hardware, and software information, browser,app list which the user installed, memory capacity .
We may analyze the model, capacity and unique device identifier of the user, in order to identify the uniqueness of the user and protect your data security; and may analyze the user's financial app installation for the understanding of user's recent financial status in order to provide a reasonable credit rating based on our big data model.
Location Information
We may collect the location information of your device and upload it to our servers in order to ensure the safety of your account, including the GPS, the longitude, latitude, location area, location area code, positioning mode, positioning time, and other position-related information of the user equipment. When you log in to our Application in a different location, we will confirm with you to ensure there is no risk to your account.
Camera and Image
We may need your camera license so that you can easily scan or photograph the documents required for your loan application and photograph will be sent to our server(https://api.ngnairacup.com).These documents help to prove your true identity and enrich your credit report, which is one of the important steps of KYC.
Installing Applications
We may need to compile a list of metadata information of the installed applications including the application name and package name of each application installed on your device to assess your creditworthiness and enrich your profile with pre-approved custom loan offers.
Cookies
We may set cookies to track your use of our Application or Website. Cookies are small encrypted files, that a site or its service provider transfers to your device’s hard drive that enables the sites or service provider’s systems to recognize your device and capture and remember certain information. By using our APP, you signify your consent to our use of cookies.
Third Party Information
In order to fulfill your requests for certain Service, we may collect, on your behalf, your account and other personal information from Third Party that you register under your account via their Service.Third Party Platforms may including social networking platforms, such as Facebook, Google and other similar platforms which could assist us to improve your experience with the Service. We may also collect data from Third Parties such as credit bureaus and other financial institutions.
USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION
We understand the importance of your information and ensure that it is used for the intended purpose only. We access, store and use the information we collect from you in accordance with the applicable laws to provide our Services, to research and develop new ones subject to the limitations set out in this Privacy Policy.
We use the information to:
1. resolve disputes;
2. troubleshoot problems;
3. help promote a safe service;
4. analytical analysis;
5. marketing purposes;
6. measure consumer interest and satisfaction in our products and services;
7. inform you about online and offline offers, products, services, and updates;
8. customize your experience;
9. detect and protect us against suspicious or illegal activity, fraud and other criminal activity;
10. enforce our terms and conditions;
11. improvement of our services and as otherwise described to you at the time of collection
12. In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users' activity on our Platform.
PURPOSE OF COLLECTING INFORMATION
The intended purpose of collecting information provided by you is to:
1. establish identity and verify the same;
2. to complete your Video KYC;
3. monitor, improve and administer our Platform;
4. provide our service i.e. perform credit profiling for the purpose of facilitating loans to You.
5. design and offer customized products and services offered by ourselves /our third party financial partners;
6. analyse how the Platform is used, diagnose service or technical problems and maintain security;
7. send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform;
8. manage Our relationship with You and inform You about other products or services We think You might find of some use;
9. conduct data analysis in order to improve the Services / Products provided to the User;
10. use the User information in order to comply with country laws and regulations;
11. conduct KYC for ourselves /our third party lending partners based on the information shared by the User;
12. use the User information in other ways permitted by law to enable You to take financial services from our lending partners.
13. We will use and retain the information for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.
DISCLOSURE TO THIRD PARTIES
We will share Your information with only our registered third parties including our regulated financial partners for provision of Services on the Website/ App. We will share Your information with third parties only in such manner as described below:
1. We disclose and share Your information with ourselves /our third party partners for facilitation of a loan or facility or line of credit or applying a loan;
2. We share Your information with ourselves /our third party partners in order to conduct data analysis in order to serve You better and provide Services our Platform;
3. We may disclose Your information, without prior notice, if we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply Our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
4. We will disclose the data / information provided by a User with other technology partners to track how the User interact with the Platform on Our behalf.
5. We and our affiliates may share Your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur than any business entity (or the new combined entity) receiving any such information from Us shall be bound by this Policy with respect to your information.
6. We will disclose the information to ourselves /our third party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third party data source providers;
7. We will share Your information under a confidentiality agreement with the third parties and restrict use of the said Information by third parties only for the purposes detailed herein. We warrant that there will be no unauthorised disclosure of your information shared with third parties.
8. By using the Platform, you hereby grant your consent to the Company to share/disclose your Personal Information (i) To the concerned third parties in connection with the Services; and (ii) With the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities, in accordance with applicable laws of Sri Lankan.
9. We shall disclose your Video KYC journey to the relevant regulatory authorities as a part of our statutory audit process. Please note that your NIC number shall never be disclosed.
10. In case we use or disclose your information for any purpose not specified above, we will take your explicit consent.
CHANGES IN THIS PRIVACY POLICY
We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.
ACCESSING YOUR INFORMATION / CONTACTING US
At any point of time Users can choose to edit/modify or delete/withdraw any Personal Information shared for use of the Platform. Please note that deleting or withdrawing information may affect the Services we provide to you. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.
YOUR PRIVACY CONTROLS
You have certain choices regarding the information we collect and how it is used:
1. Device-level settings: Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android device for access to Camera or Audio permissions.
2. Delete your entire App account.
3. You can also request to remove content from our servers based on applicable law or by writing to our Grievance Officer.
SECURITY PRECAUTIONS
The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.
Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in Sri Lankan as per applicable law.
We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.
In addition, the Website and App have been certified for the following security certifications:
1. ISO 9001: being the international standard that details requirements for a quality management system (QMS). Organizations use the standard to demonstrate the ability to consistently provide products and services that meet customer and regulatory requirements with the requisite security protections.
2. ISO 27001 (formally known as ISO/IEC 27001:2005): is a specification for an information security management system (ISMS) and is the suggested level of certification required under the Information Technology Act, 2000. An ISMS is a framework of policies and procedures that includes all legal, physical and technical controls involved in an organization’s information risk management processes.
3. We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:
a. We use encryption to keep your data private while in transit;
b. We offer security feature like an OTP verification to help you protect your account;
c. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
d. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
e. Compliance & Cooperation with Regulations and applicable laws;
f. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
g. Data transfers;
h. We ensure that NIC number is not disclosed in any manner.
i. We or our affiliates maintain your information on servers located in Nigeria. Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000 and rules made thereunder
j. When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
LINKS TO OTHER SITES
Our Platform links to other websites that may collect information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we’re only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the Website, please ensure You go through the privacy policies of each of those websites. Their data collection practices, and their policies might be different from this Policy and We do not have control over any of their policies neither do we have any liability in this regard.
YOUR CONSENT
By using the Platform and by providing your information, you consent to the collection, sharing, disclosure and usage of the information that you disclose on the Platform in accordance with this Privacy Policy.
If we decide to change our Privacy Policy, we will post those changes on this page so to make you aware of the information we collect, how we use it, and under what circumstances we share and disclose it.
GRIEVANCE OFFICER
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below for your reference:
Email：NairaCupHELP@GMAIL.COM