Privacy Policy

INTRODUCTION

Crendly (“Crendly”, “we” “our” “us”) values your privacy and the security of the information you share with us. This Privacy Policy explains how we collect, use, disclose and safeguard the information we obtain from you in relation to your use of our website, product, or services. It applies to our website and all related sites, applications, services, and tools regardless of how you access or use them.

By using our website, products, or services, you consent to the terms and practices contained in this Privacy Policy and grant us the right to collect and process your data in accordance with the terms of this Policy.

Our website and services are not directed to children under 18. We do not knowingly collect information from children under 18. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

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THE INFORMATION WE COLLECT

When you use our website or service, we may collect certain types of information about you including the following:

Information you provide to us

This includes but is not limited to your personal data (such as your full name, phone number(s), email address, home or office addresses, product and service preferences, and responses) and bank verification number for registration and compliance purposes.

Information we collect automatically

This includes but is not limited to your IP address, browser type, mobile device ID, device type, operating system version, connection information, mobile network information, location derived from GPS-enabled services, information based on your usage of the service such as time, date and duration of your use, referral URLs, search terms and search history, camera, contact list, browsing history, purchase history and advertisement interactions.

Information we obtain from 3rd Parties

We may retrieve additional personal information about you from third parties like the credit bureau and other identification/verification services such as your financial institution and payment processor. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our services through your Crendly account we will keep records of your transactions and collect information of your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislation. In providing you with the services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and your personally identifiable information is treated in a safe and secure manner.

Mobile Analytics

We deploy mobile analytics software which allows us to effectively understand the functionality of the Platform on your device. This software may record information such as how, when, and where you use the application, the events that occur within the application, aggregated usage, performance data, and how the application was downloaded, such as your IP addresses, browser type, and internet service.

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WHY WE COLLECT YOUR INFORMATION

We collect your information to ensure your easy and seamless access to our services. We use the information we collect for the following purposes:

  1. To enable us to provide you with a personalized experience of our product and services.
  2. To communicate with you and provide you with information on our Services, such as marketing content, newsletters, and service update. However, we will provide you with an option to unsubscribe if you do not want to hear from us
  3. To provide support services to you.
  4. To process your orders and requests.
  5. To analyse and understand your use of our products and services.
  6. To protect against illegal, malicious, and fraudulent activity.
  7. To analyse and improve the quality of our services and offerings.
  8. To facilitate your interactions with our social media platforms.
  9. To analyse and learn about our users’ demographics, interests, and behaviour.
  10. To identify and repair errors and bugs on our platforms.
  11. To facilitate the dissemination of information about our services and our partners.
  12. To comply with court orders, legal processes, or applicable law, including retaining personal data or responding to any government or regulatory request.
  13. For any other purpose for which you provide your consent.

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SHARING YOUR INFORMATION WITH THIRD PARTIES

We may sometimes share the information we have collected from you with third parties. These third parties include our affiliates, subsidiaries, partners, financial services providers, third-party vendors, and suppliers who render services for us or on our behalf and our professional advisers (such as our auditors, accountants, lawyers, etc.). We may share the information to facilitate the seamless delivery of our services or in compliance with applicable legal requirements and assist law enforcement agencies by responding to requests for the disclosure of information in accordance with local laws. Thus, we may share information with third parties for everyday business purposes, including:

  1. Other Crendly users who are interested in considering your loan request, including Crendly users other than the one who ultimately funds your loan request (the “Lender“)
  2. Our banking partner and a debt collection agency.
  3. Credit bureaus to report the repayment status of loans made through the Platform, as permitted by law
  4. Official reporting in line with regulatory compliance, statutory requirements, court order, and any other legal procedure.

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DATA RETENTION PERIOD

We will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations, or verify your information with a financial institution. Crendly is statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud, and be in compliance with laws and regulatory guidelines applicable to us, our banking providers, and card processors. Therefore, even after closing your Crendly account, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by Crendly where possible. For all Personal Data and records obtained, used, and stored by Crendly, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity, and requirement to retain. The length of storage of Personal Information shall, amongst other things, be determined by:

  1. The contract terms agreed between Crendly and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
  2. Whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require Crendly to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
  3. Whether the transaction or relationship has statutory implication or a required retention period; or
  4. Whether Crendly has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

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UPDATES TO THIS POLICY

We reserve the right to periodically update and modify the terms of our Privacy Policy without notice. Changes to this Privacy Policy will take effect on the last updated date.

1. Introduction

This Privacy Policy together with our Terms of Use and Loan Account Agreement  explains how we collect and process personal data received from you on our website and mobile app and via electronic communications. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By continuing to use our Application, visit our website, or accessing any of our services, you consent to our usage of your personal information as described in this Policy. Unless otherwise defined, terms used in this Privacy Policy have the same meanings as in our Terms of use.

If you have any comments on this privacy policy, please email them to support@crendly.com.

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2. What We Do

Crendly is a peer-to-peer lending application by Humexid Limited (“Crendly”) that connects verified borrowers to verified lenders with the goals of receiving a loan and funding a loan respectively. Crendly will enable borrowers to obtain loans directly from lenders, cutting out middlemen and reducing the risk of default.

We collect several types of information for various purposes to provide and improve our Service to you. All information supplied by you as defined under the Terms of Use is covered by the provisions of the laws of Nigeria and other extant laws and regulations regarding the use and management of personal data.

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3. Types of Data Collected

We may collect and process the following data about you:

Information you give us about you (submitted information)
  • Personal Data: While using our Service, we will ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information that we collect includes, but is not limited to, email address, BVN, phone number, date of birth, personal identification documents, personal financial statements, third parties (e.g. banks, clearinghouses, payment service providers, credit bureaus, etc.), interaction and communication with our staff, and any communication with Crendly.
  • Information you put into forms or surveys on our site at any time;
  • A record of any correspondence between us; (for example, by e-mail or chat);
  • 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, and reporting a problem with the App, our Services, our Site or any of Our Service Sites.

This information may include your name, address, e-mail address and phone number, the Device’s phone number, age, username, password and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description and photograph.

  • Details of transactions you carry out through our platform;
  • Details of your visits to our site and the resources you use; and
  • Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers.
II. Information we collect about you and your device each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:
  • 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, or your Device’s location and time zone setting (Device Information);
  • Information stored on your Device, including contact lists, call logs, SMS logs, social media accounts, other financial applications, photos, videos or other digital content (Content Information);
  • Data from your use of any other third-party application on the Device or the Service Sites; and
  • 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).
iii. Location information.

We also use GPS technology OR other location services to determine your current location. You can withdraw your consent to our collection, processing or use of this information at any time by logging out and uninstalling the App from your Device.

iv. Information we receive from other sources (Third Party Information).

Due to the nature of the Services which we provide, we are required to work with a number of third parties (including credit reference agencies and mobile network providers) and we may receive information about you from them.

v. Unique application numbers.

When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Under Nigeria NDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

  1. you have given consent to the processing of your personal data for one or more specific purposes;
  2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  3. processing is necessary for compliance with a legal obligation to which we are subject;
  4. processing is necessary to protect the vital interests of you or of another natural person;
  5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

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4. Cookies And Usage Data

  • Usage Data: When you access the Application or our services by or through a mobile device or web service, we may collect certain information automatically, including, but not limited to, the type of device you use, your device unique ID, the IP address of your device, your operating system, the type of internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).
  • Tracking & Cookies Data: We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Application.

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5. Use Of Data

We will use your collected data for various purposes including:

  • Establishing your identity and assessing your eligibility for our products and services
  • Updating and enhancing our records
  • Customer relationship management
  • Risk identification and management
  • Investigation and prevention of illegal and fraudulent activity
  • Designing and administering our products and services
  • Conducting and improving our business and improving customer service experience
  • Complying with legal obligations and assisting law enforcement agencies
  • Identifying and informing you about other products and services that we think may be of interest to you, and changes to the Application and Service.
  • To allow you to participate in interactive features of the Application or our Services when you choose to do so.
  • To monitor the usage of the Application and Services
  • To detect, prevent, and address technical issues.

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6. Transfer Of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Nigeria and choose to provide information to us, please note that we transfer the data, including Personal Data, to Nigeria and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

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7. Disclosure of Data

We may disclose your Personal Data in the good faith belief that such action is necessary:

  • To comply with a legal obligation
  • To protect and defend our rights or property
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of our Services or the public
  • To protect against legal liability.

To the extent that it is necessary and permitted by law, we may reveal or share your information with the following people:

  • Our employees
  • Our subsidiaries, affiliates, and strategic partners
  • Financial services providers including other banks, clearing houses, credit bureaus, payment service providers, etc.
  • Courts, regulators, government agencies, law enforcement agencies, etc.

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8. Security Of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Crendly takes the safeguarding of your personal information very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable laws and regulations to ensure the security of your information, prevention of unauthorized access and use, accidental or unlawful alteration and destruction; and other unlawful or unauthorized forms of processing.

We regularly update our security protocols and processes to meet industry standards. If you have been provided a password to grant you access to the Application or specific areas on our website, you are responsible for keeping this password confidential. You must not share your password or other authentication details with anyone, Crendly will not be responsible for any losses you may incur if you disclose your password and/or authentication details.

We will store and retain your data for as long as is necessary for the purpose(s) that it was collected. Storage of your data is also determined by legal, regulatory, administrative or operational requirements

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9. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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10. Links to Other Sites

Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

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11. Your Data Privacy Rights

  • Right to Rectification: You can modify or change their email, password, PIN, and profile picture via your profile.
  • Right of Access, Right to Erasure, Right to Restrict Processing: You can request access or erasure of their personal information, as well as request restrictions on further processing of their personal information by contacting us at support@Crendly.com. Please allow up to 30 days for requests to be processed. We reserve the right to charge a reasonable fee to process excessive or repeat requests.
  • Right to Withdraw Consent: You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send, or by adjusting your Marketing Preferences in your profile. You also have choices with respect to cookies, as described above. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Application and website may not work properly in your case.
  • Right to lodge a complaint with a supervisory authority: Should you feel your data privacy rights are not being adequately protected by us, you have the right to lodge a formal complaint with the appropriate supervisory authority.

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12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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13. Contact Us

Contact us if you have questions regarding your data privacy rights or would like to submit a related data privacy right request, please email us at support@Crendly.com. Please allow up to 30 days for requests to be processed. The Company reserves the right to charge a reasonable fee to process excessive or repeat requests.

Contact us if you have any questions about this Privacy Policy, please contact us: support@Crendly.com.