Privacy and Policy

OUR TERMS & POLICIES

    This Privacy Policy (Policy) together with our Terms of Use and Loan Account
    Agreement as set out at here and any additional terms of use applies to your use of:

  • a. LibertyCredi mobile application software (App) available on Google Play Store and the Apple App Store (collectively App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • b. Any of the services accessible through the App (Services) or those available on the App Site or other sites of ours or other third-party Sites (Service Sites).
  • This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

    Please read the following carefully to understand our views and practices regarding how we will treat your personal data. By downloading the App, you confirm that you have read, understood and accept the terms of this Policy set out hereunder. You also consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy.

INFORMATION

    A. Information we may collect from you

    We may collect and process the following data about you.

    i. Information you give us about you (Submitted information):

    This may include:

  • information provided by filling in forms when visiting our App;
  • information provided by corresponding with 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 App Site or any of Our Service Sites.
  • This information may include your name, address, e-mail address and phone number, the Device's IP address 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.

    B. Information we collect about you and your device

      Each time you use our App, 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, 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).

    C. 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.

    D. 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.

    D. 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.

TRACKING AND COOKIES

    We may use mobile tracking technologies and cookies to distinguish you from other users of the App, App Site, or Service Sites. This helps us to provide you with a good experience when you use the App or browse any of the Service Sites and also allows us to improve the App and Our Service Sites.

USES MADE OF THE INFORMATION

    We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.

  • Information collected by us shall be used for the purpose of determining whether or not to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan. They may also be used to maintain the Service, provide customer care and support, provide analysis for the improvement of the Service, notify you of changes made to the Service and detect and prevent technical issues.
  • Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied for a loan on any given day).

DISCLOSURE OF YOUR INFORMATION

    We may disclose some or all of the data we collect from you when you download or use the App to credit reference bureaus.

APP PERMISSIONS

    To assess your eligibility, determine the best offer for you and disburse your loan faster, we would need the following permissions from you.

  • SMS
    We collect all your SMS data but only monitor your messages related to financial transactions. To be specific, we will monitor the name of the sender, the description and the amount of transaction to perform credit risk assessment. This enables faster and quicker loan disbursal. No personal SMS data is monitored, read, stored or shared. We will upload SMS data to LibertyCredi server with high level protection and will not be shared with any third party.
  • CONTACT
    We gather your phonebook contacts which includes their phone contact names, phone numbers, contact added date to augment your credit profile, additionally, and this can allow you to choose your references in the loan application or share our app invitation to your friends easily. We will upload Contact data to the LibertyCredi server with high level protection.
  • LOCATION
    Collect and monitor information about the location of your device for customer risk assessment and scoring. We will upload location data to the LibertyCredi server with high level protection.
  • MEDIA
    Collect and monitor information about the location of your device for customer risk assessment and scoring. We will upload location data to our servers and ensure it is secure with high level protection.
  • DEVICE
    Collect and monitor specific information about your device including your device name, model, region and language settings, device identification code, device hardware and software information, status, usage habits, unique device identifiers like IMEI and serial number to uniquely identify the device and ensure that unauthorized devices are not to act on your behalf to prevent frauds. We will upload collected data to the LibertyCredi server with high level protection.

DATA STORAGE

    Regarding all the collected information, we will store it with high level protection in accordance with the data protection laws in Nigeria

    How do we use your data? We collect certain data to be able to provide the Service to you. We also collect data for use in verifying your identity and creating credit scoring models to determine what Loans can be offered to you. We also use this data for purposes of collections and credit reporting.

THE DATA WE COLLECT

    When you register for the Service, we will collect your bank number and telephone number and may also collect your name, age, email address or other contact information. With this information, we cross-check your identity with third parties including the person you have provided as your emergency contact. We will also collect data from your device for our credit scoring system. This includes information relating to your device, such as device maker and model, operating system, installed software applications, and the unique user identifier. We also collect your email and phone-book contacts and information related to device activity such as SMS logs and GPS location information. To supplement this information, we also collect data from third parties such as credit bureaus and other financial institutions.

    By enabling access to Contacts, Calender, Registered Accounts which might include Social Accounts, Storage Information, (Only if correspondent module is used) and Installed Applications, we will collect data to better evaluate your loan application. This information is only accessed once, collected in the form of metadata, is shared and used by credolab only to calculate a more accurate credit score.

    By registering for the Service, you authorize the collection and processing of the foregoing data.

    We will ensure that your data is protected to a strict standard.

    We may disclose your personal information to any member of our group, which means our subsidiaries, affiliates, our holding company and its subsidiaries.

    We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if LibertyCredi or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or
  • in order to: enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

HOW WE USE THE PERSONAL DATA COLLECTED?

    We will process (collect, store and use) the information you provide in a manner compatible with the Nigeria Data Protection Regulation (NDPR). We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services.

    We only processes personal information for the purposes as described in our Privacy Policy and/or the supplementary privacy notices for specific services. In addition to the above, such purposes include:

  • Providing our services to users, including the display of customized content;
  • Auditing, research and analysis in order to maintain, protect and improve our services;
  • Ensuring the technical functioning of our network and Developing new services.
  • We process personal information by referring to the supplementary privacy notices for particular services.

    • Log information
      When you access our apps/web, our server automatically records information that your browser sends whenever you visit a website.
    • User communications
      When you send email or other communications to We, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. Retention of data shall be in line with NDPR/CBN retention policy
    • Affiliated sites
      We offer some of our services in connection with other web sites e.g. Websites of our subsidiaries. Personal information that you provide to those sites may be sent to us in order to deliver the service. We process such information in accordance with this Privacy Policy. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies. 

WHY WE COLLECT AND STORE YOUR PERSONAL DATA?

    We collects your personal data in order to provide you with the required loan service. When you sign up for any of the loan products (on line or other service that requires registration, personal information such as your name, email address and account password are required. We use the information you submit under your account to provide you customer centric service. We are committed to ensuring that the information we collect are used appropriately for the purpose they were collected, and does not constitute an invasion of your privacy.

    In terms of being contacted for marketing purposes We shall contact you for additional consent.

ON WHAT LEGAL GROUNDS DO WE PROCESS PERSONAL DATA?

    We will use your personal information based on some legal basis (a valid legal reason). Our legal basis will be one of the following:

    • Keeping to our contracts and agreements with you
      We need certain personal information to provide our services and cannot provide them without this information.
    • Legal obligations
      In some cases, we have a legal responsibility to collect and store your personal information
    • Legitimate interests
      We sometimes collect and use your personal information, or share it with other organisations, because we or they have a legitimate reason to have it and this is reasonable when balanced against your right to privacy.
    • Consent
      Where you've agreed to us collecting your information, for example by using the website to apply for a loan or when you have ticked a box to indicate you are happy for us to use your personal information in a certain way.

WHAT ARE YOUR PRIVACY RIGHTS?

    You can decide not to disclose any of your information to us but keep in mind that some information may be needed to register with us or take advantage of some features of our products or services.

    You have the right to ask us not to process your personal data for marketing purposes and to withdraw your consent at any time. Please note that the withdrawal of your consent will not affect the lawful processing of data which we have obtained based on your previous consent. We will usually inform you (before collecting your data) if we intend to use your data for the aforementioned purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.

    You can also opt-out of receiving certain promotional or marketing communications from us at any time by using the unsubscribe link in the emails communications we send, or by filling out any request form we set in place. Please note that if you have an account with us and you opt out of receiving promotional and marketing related communications from us, we may continue to send you non-promotional communications, e.g. service-related emails.

HOW CAN YOU EXERCISE YOU PRIVACY RIGHTS?

    In case you like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), including the right to request a copy of standard contractual clauses, you can send us an email to DPO, e.g. dpo@libertyng.com. Our privacy team will inspect your request and revert back as soon as possible. Please note that we may still use any Personal Information that does not identify any individual and may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements.

    We also want you to know that you have a right to lodge a complaint with a supervisory authority (e.g. Nigeria Data Protection Bureau (NDPB)) should you feel unsatisfied with our treatment of your Personal Information.

DO WE SAVE COOKIES ON DEVICE?

    When you use our website, cookies are used to distinguish you from other users of our website. In this way, we provide you with a good experience when you browse our website and also allows us to improve our site. By visiting our website, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Policy.

WILL WE SHARE PERSONAL DATA WITH ANYONE ELSE?

    Your personal information shall only be shared with other companies or individuals in the following limited circumstances:

  • If, we have your consent as required for the sharing of any sensitive personal information
  • We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with the General Data Protection Regulation and the Nigeria Data Protection Regulation and any other appropriate confidentiality and security measures. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures.
  • We have a good belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety, its users or the public as required or permitted by law.
  • If we become involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

WILL YOUR PERSONAL INFORMATION GO OUTSIDE THE COUNTRY?

    Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate, in order to enable us to use the information in accordance with this policy. Any such information transferred to other countries shall be in compliance with the Act and the Regulations of NDPR.

WANT TO KNOW OUR POLICY ON RETENTION OF PERSONAL DATA?

    We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary, but we depend on our users to update or correct their personal information whenever necessary. We is required to retain information it collects from you in accordance with the law, such as, information needed for audit purposes, information needed for review purposes, information needed for legal purposes, etc. How long certain kind of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs

CAN YOU FIND OUT THE PERSONAL DATA THAT WE HOLD?

    We on your request, can confirm what information we hold about you and how it is processed. If we hold personal data about you, you can request the following information:

  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Libertycredi or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third party or international organization, information about how we ensure this is done securely. The Attorney General of the Federation will approve sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (NDPB).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

WHERE WE STORE YOUR PERSONAL DATA

    The data that we collect from you may be transferred to and stored at a destination outside your country of origin or residence (as applicable) where the data protection laws may differ from those in your jurisdiction. It may also be processed by staff operating outside your country of origin or residence (as applicable), who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests on the Service Sites. By submitting your personal data, you agree to the collection, transfer, storing or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this Policy.

SECURITY OF DATA

    We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your 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.

    Notwithstanding the undertaking above, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, using global best practices, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

    Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences.

    If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. You are reminded to log off from your account and close the browser when finished while using a shared computer.

YOUR PRIVACY RIGHTS

    You have the following privacy rights:

  • Right to Rectification - You can modify or change your name, email, password, and mobile login PIN through your profile.
  • Right of Access, Erasure, and Restrict Processing - You can request access or erasure of your personal information, as well as request restriction on further processing of your data/personal information by contacting us at support@libertyng.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 repeated 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 can 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 Service 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.

LEGAL AGE

    We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child or children have provided us with personal data, please contact us at support@libertyng.com. If we become aware that we have collected personal data from children without verification of parental consent, we shall take steps to remove that information from our servers.

LINKS TO OTHER SITES

    The App may provide hypertext links to other sites operated by other people. Using such a link means you are leaving the App. We take no responsibility for, and gives no warranties, endorsements, guarantees or representations in respect of, linked sites. We are not responsible for the privacy practices, nor do we accept any liability in connection with the content of, such websites or applications, which will in some cases have their own privacy policies tailored for the particular business practices in which they operate. Any concerns regarding any external link should be directed to its website or app administrator.

CHANGES TO THE POLICY

    Any changes we may make to this Policy ln the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Service Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. In any event, by continuing to use the App or any Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.

CONTACT US

    Contact us by sending an e-mail to support@libertyng.com if you have any questions about this Policy

    27, Alara Street, Off Commercial Avenue, Off Herbert Macaulay Street, Sabo-Yaba, Lagos State.

    hello@libertyng.com

    +234 1270 6255

    LibertyCredi is a product of LibertyPay Limited. Licensed as a Money Lender by the Lagos State Government of Nigeria.