Privacy Policy

Lucred Technology Limited (Lucred or We, Our, Us) respect your privacy and are committed to protecting your Personally Identifiable Information (PII) that may be collected through your use of our website or mobile application (together, Site) or in applying for or receiving any of our products or services (Services). This privacy policy (Policy) describes how we collect and use your PII and how you can control that use. Please read this Policy carefully. By Clicking the continue or Accept icon or any other icon that indicated agreement with this Privacy Policy, downloading the Lucred App and applying for any of our services including but not limited to the Credit Application, you agree to our collection, use, and sharing of your PII as described in this Policy.

WHEREAS:

This Loan Agreement is a financial services and an end-user License (access to use the Lucred Mobile Application) agreement between you (End-user Borrower or you) and Lucred Technology Limited, a company duly incorporated under the laws of the Federal Rebublic of Nigeria, Approved by the FCCPC and Licensed as a Money Lender under the Moneylenders Act (Lucred, Lucred Credit, Lucred Technology Limited, Lucred App, us or we) for the mobile application software, the data supplied with the software and the associated Services hereinafter defined in this agreement (the App).

YOU AND LUCRED HEREBY AGREE:

This Agreement (together with our Privacy Policy) sets out the complete terms and conditions (the Terms and Conditions) which shall be applicable to the Account (as hereinafter defined) opened by you with Lucred Technology Limited.

Introduction

This privacy policy (this "Privacy Policy") explains how personal information is collected, used, stored, and disclosed by Lucred Technology Limited ("Lucred", "we", "us", and "our"). This Privacy Policy applies to users of our websites, applications, and other services (collectively, our "Services"). This Privacy Policy is part of our Terms of Use. By accessing or using our Services, you agree to this Privacy Policy and our Terms of Use. If you do not agree to every provision of this Privacy Policy and our Terms of Use, you may not access or use our Services.

Consent

We'll ask for your consent to:

Send you promotional emails or push notifications. You can opt out in your app's 'Settings'.
Track your phone's location if authorized, to protect you against fraud.
Show your profile picture if you add one.
Share information about you with companies we work with when we need your permission.

How We Collect Data

Information You Provide Us

When you sign up for a Lucred Account:

Personal details like your name, date of birth, and place of birth.
Contact details like home address, email, phone number, and BVN.
Information about your indenture, such as a copy of your ID document.
Financial details, such as your employment status and the industry you work in, annual income, number of dependents, residential status and monthly housing costs.

When you sign up fo or use our services

Details you give us when you sign up for a specific service. If you apply for card or credit we will ask for details about financial circumstances and reason for borrowing.
Details you give us which we pass to our partners when you let us know you’re interested in their services.
Information you give us through our chat platforms or disclose to our customer service representatives. Answers you give to surveys about Lucred and our services.

Information We Collect or Generate when you use the app and our services

We collect this information to give you services in a safe and lawful way, and to keep improving them. This includes:

details about payments to and from your Lucred account, card and any loans or credits you take out.
details about services from us and our partners that you express interest in.
details about you use our app.

Information From Third Parties and External sources

When you sign up for a Lucred account, we search your record at;

a credit reference or consumer reporting agency.
Fraud prevention companies and agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal duties.

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:

Device Information:: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your Lucred account.
Log Information:: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:
- The mobile network and operating system you use, so we can analyse how our app works and fix any issues
- The Device’s Internet Protocol (“IP”) address
- Identification numbers associated with your Devices
- Device event information, such as crashes, system activity, and hardware settings
- Your location if you’ve authorized tracking, so we can help protect you against fraud.
- Date and time stamps of transactions
- System configuration information
- Other interactions with our Services
- Your phone SMS for financial profiling
- Your phone contacts whether or not they use Lucred and if you’ve authorized access to your phone book.

Information Collected Through Cookies and Similar Technologies

We use cookies to personalize our Services for you and to collect aggregate information about 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: 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 Lucred account to perform.
Persistent cookies:they 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 Lucred 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. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. 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.

Data Collected

How We Use Information

The Nigerian Data Protection Laws say we need to have a lawful basis for using your personal data. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent. In this section, we explain which one we rely on to use your data in a certain way.

We need to use your data for a contract with you or to enter into one. We may use your data to:

Consider your application.
Provide services in line with our terms and conditions.
Send messages about your account or services.
Exercise our rights under contracts we’ve entered into with you, like managing, collecting and recovering money you owe us.
Investigate and resolve complaints or other issues.

We need to use your data to comply with the law. We:

confirm your identity when you sign up or get in touch.
Check your record at fraud prevention agencies.
Prevent illegal activities like money laundering, tax evasion and fraud.
Check your credit history and ask about your reasons for applying for our card or financial products and other details about your financial circumstances so that we can make responsible lending decisions.
Keep records of information we hold about you in line with legal requirements.
Adhere to banking laws and regulations (this means we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).

When it’s in our legitimate interest. We need to use your data for our legitimate interests, or those of a third party. This means using data in a way that you might expect us to, for a reason which is in your and/or our (or a third party’s) interest and which doesn’t involve overriding your privacy rights.

Product development and marketing: We:

We check your record at credit reference agencies when you sign up to see if we can offer you our card or credit tell you about products and services through the app or other channels, like social media companies, based on how you use our products and services and other information we hold about you. We do this so we can make sure our marketing is useful. That includes instructing platforms to show or not to show Lucred adverts to existing customers. We don’t share any identifying information with social media companies other than your mobile advertising ID. You can disable or reset your mobile advertising ID in your device’s operating system.
Track, analyse, and improve the service we give you and other customers and how you respond to ads we show. We may ask for feedback if you’ve shown interest in a service. We do this so that we can make our products better and understand how to market them.

Special Features

Show where you were when you used the Lucred card or account.
Give a report on how you’ve spent using your Lucred card.

Security and Business Management

Protect the rights, property, or safety of us, our customers, or others.
Carry out security and maintenance checks to ensure our app, website, and services run smoothly.
Manage Lucred’s business risk and financial affairs while protecting customers and staff.

Personal Data - Who We Share Your Data With

Here we mean companies that help us provide services you use, and need to process details about you for this reason. We share as little information as we can and encrypt and/or make it impossible for you to be identified by the recipient where possible (for instance by using a User ID rather than your name).

companies that make our Lucred cards.
card producers and networks, like MasterCard.
Know Your Customer (KYC) service providers that help us with identity verification or fraud checks.
cloud computing power and storage providers.
our business intelligence and analytics platform provider.
companies that help us with functional analytics (to help us solve technical issues with the app for instance).
companies that help us with marketing (but we won’t share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time).
software companies that we use for emailing you like, or for processing and storing email communications with you like.
companies that help us with customer support.
companies that offer benefits or rewards through special programmes you sign up to via the app.

Credit Reference Agencies

Credit reference agencies (CRAs) give lenders information about borrowers to help them make responsible lending decisions. Banks share details about their customers to help CRAs maintain up-to-date information about people’s financial status. We work with some of these CRAs.

When you sign up and for as long as you’re a customer, we’ll exchange details about you with CRAs. This includes:

Your name, address, and date of birth.
accounts you have, including when you opened them and money going into them (if you owe us money, we’ll also share your balance).
credit applications you’ve made and limits you’ve turned on.
if you’ve borrowed, details of your loan and repayments (like whether you repay in full and on time).
fraud prevention information.

We’ll use this information to comply with our legal duties and when it’s in our ‘legitimate interest’ to:

verify your identity and make sure what you’ve told us is true.
help detect and prevent fraud and money laundering.
assess whether you can afford to make repayments if you borrow.
manage your account with us.
trace and recover debts.
make sure our offers are relevant for you.

Fraud Prevention Agencies

When you apply for an account, we check your record with fraud prevention agencies (FPAs). During the application process and after you become a customer, we may share information about you with them to help prevent fraud and money laundering when it’s in our ‘legitimate interest’. If we detect fraud, we may stop activity on your account or block access. Other organisations may use information we share with FPAs about fraud to refuse their services, finance or employment.

Anyone you give us permission to share it with. We tell you in the app when we need your consent to share your data with: companies that introduce their own services via the Lucred app, like energy switching, insurance or remortgaging. other apps. other banks if you use account switching or aggregation services. people you’ve asked to represent you, like solicitors. Law enforcement and other external parties.

We may share your details with: authorities that spot and stop financial crime, money laundering, terrorism and tax evasion if the law says we have to, or if it’s necessary for other reasons. the police, courts or dispute resolution bodies if we have to. other banks to help trace money if you’re a victim of fraud or other crimes or if there’s a dispute about a payment. any other third parties where necessary to meet our legal obligations. We may also share your details with people or companies if there’s a corporate restructure, merger, acquisition or takeover of our company.

Personal Data Principles

Do Not Track Signals

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

Opt-Out Rights

If you do not wish to receive offers or other notices from us, you can opt out by contacting us or following the "unsubscribe" instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your Lucred account or related transactions with us..

However, you cannot opt out of communications related to your Lucred account or transactions.

Accessing Your Information

You must notify us of any change in your Personal Information by updating your Lucred account profile through our Services. Any changes will affect only future uses of your Personal Information.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

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

We have, and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL).

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Lucred account and do not share them with others. If we receive instructions using your Lucred account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Lucred account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Lucred accounts, and to remove or edit content.

Protecting Children’s Privacy

Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.

Links to Third-Party Websites

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

Changes to Our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or 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 access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.