Data Protection & Privacy Policy
Introduction

This Data Protection & Privacy Policy (“policy”) describes how personal data is collected, handled, used, stored and disclosed by The Creditville Group Limited & its subsidiaries (collectively referred to as “Creditville”) to meet the standards set by the Nigerian Data Protection Regulations 2019 and applicable law. By this policy, our users, business partners, clients, suppliers and the general public (hereinafter referred to as “you” “your” “their” or “data subject”) know how we use and look after their personal data, their privacy rights and how we plan to protect them. Any reference to "we" "us" "our" “Creditville” and “the Company” is to Creditville and its subsidiary companies, namely -

This Policy ensures that Creditville maintains best practices and complies with data protection policies in force, protects the rights of all its stakeholders, is open about how it stores and processes personal information and protects itself from the risks of a data breach

Policy scope

This Policy applies to all staff (whether permanent, contract or interns), contractors, suppliers of Creditville. It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the NDPR and includes but is not limited to the names of individuals, postal addresses, email addresses, date of birth, sex and telephone numbers

Application of this Privacy Policy

This Privacy Policy applies generally to the business of Creditville and sets out our approach to personal data, inclusive of personal data of our business partners, clients, suppliers and the general public ("Users"). This Privacy Policy applies to the systems, operations and processes of Creditville that involve the collection, processing, use, storage, and disclosure of personal information. It applies to the use of our websites, applications, other online services and/or any related services, sales, marketing, promotional or events, and social media activities (collectively, our "Services"). For our Users, this Privacy Policy is part of our Terms of Use.

This Privacy Policy governs your use of our Services which may be accessed through a desktop, laptop, mobile phone, tablet, or other electronic device ("Device") and also applies to offline interactions with Creditville.

By accessing or using our Services, you agree to this Privacy Policy.

Information We Collect

When you contact us or interact with any of our touchpoints, register for a C- money/Touchgold/Creditville account or volunteer information to us such as information on how we can improve our product and services, we may collect personal information including but not limited to –

All collectively referred to as "Personal Information". By providing your Personal Information to us, you expressly agree to our collection, processing, use, storage, and disclosure of such information as described in this Privacy Policy.

As a User, we will also ask you to create login information for your C-money/Touchgold/Creditville account, such as a username and password. When you provide your mobile phone number and email address, we may ask for your consent to receive text or e-mail messages relating to our Services through either means.

We collect Personal Information about your transactions with us and others.

We may collect Personal Information about you from other companies such as credit reference agencies, KYC agencies etc. We may also collect your Personal Information from a User where your Personal Information is filled in a Next-of-Kin form.

Information Automatically Collected

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ("Analytics"). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include -

Cookie Policy

We use cookies to personalize our Services for you and to collect aggregate information about the usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

The cookies we use in connection with our Services include:

Session cookies :

Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their Creditville account to perform.

Persistent cookies :

Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your Creditville account or to remember your choices for our Services.

Third-party cookies :

We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services.

We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties. By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

How We Use Information

We may use Personal Information for the purposes described above, for our business and operational purposes, to offer our products and services, and products and services of third parties that we think you might find of interest e.g., airtime purchases. Only Creditville and our third-party service providers involved in providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for the stated purpose only.

We may use your email address to respond to your inquiries and to provide information about our Services. Your residential address may be used for customer due diligence purposes. You may elect not to receive promotional emails from us either by "unsubscribing" to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you emails about your Creditville account or other ongoing business relations between us, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.

We may share your Personal Information with unaffiliated third parties -

Opt-Out Rights

If you do not wish to receive offers or other notices from us in the future, you can "opt-out" by contacting us as indicated at the end of this Privacy Policy or by following the "unsubscribe" instructions in any communication you receive from us. Please be aware that if you are a User, you are not able to opt-out of receiving communications about your Creditville account or related transactions with us.

Beyond your right to opt out of our processing Personal Information, you also have the option of exercising any of the below rights with respect to your Personal Information - Request Correction to your Personal Information

As a User, you can change some of your Personal Information by updating your Creditville account profile through our Services. Changes to financial details will require you to contact us directly. If you are not a User, you can contact us as indicated at the end of this Privacy Policy to make any changes or requests on Personal Information we hold about you. Any changes will affect only future uses of your Personal Information and we may need to verify the accuracy of the new data you provide to us.

Request Access to & Restrict further processing of your Personal Information

You can request a copy of your Personal Information in our custody. Before sending you any Personal Information, we will ask you to confirm your identity. If you are not able to confirm your identity, we reserve the right to decline your request for any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information, we hold about you. Request partial or complete erasure of your Personal Information You may request that we delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Information You Share Socially

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.

Our Services may also allow you to connect with us on, share on, and use third- party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

Security and Storage of your Personal Information

We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way by a third party. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. We have put in place procedures to actively deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You also play a role in protecting your Personal Information. Please safeguard your username and password for your C-money/Touchgold/Creditville account and do not share them with others. If we receive instructions using your Creditville account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Creditville account or any other breach of security.

Changes to our Privacy Policy

Any changes to this Privacy Policy will be communicated to you and will be updated at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services or other platforms as may be required by applicable law. Acceptance of this, and any revised version of this Privacy Policy, is required for you to continue using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your use of our Services. Except as otherwise expressly stated by us, your access and use of our Services are subject to the version of this Privacy Policy in effect at the time of access or use.

Our contact details

If you have any questions, comments, or concerns regarding this Privacy Policy, please contact us at customer@creditville.ng or 0700 033 033 0