PRIVACY POLICY

1. This privacy policy (the “Policy”) together with our Terms and Conditions as set out on the Palmcredit mobile application (the “App”) and any additional terms and conditions apply to your use of the App and any of the services provided by NEWEDGE FINANCE LIMITED (“NFL”, “we” or “us”) using our App.

2. 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. The Policy also describes your rights regarding our collection, use, storage, sharing, and protection of your personal information.

3. By clicking on the button labelled “Sign Up” below and proceeding to use the App or access any of the Services (as defined below), on the App, you confirm that you have read, understood and accept the terms of this Policy as set out hereunder. You also expressly consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy and the Terms and Conditions.

4. We may amend this Policy at any time by publishing the amended terms on the App. All amended terms shall automatically become effective on the day that they are published on the App. Additionally, we will notify you of any substantive or material change in this Notice by one of the following means: updating this web page, sending push notifications, e-mails or letters, by phone or by publishing announcements on our website.

5. For the purposes of this Policy, the term “Services” shall be defined as any form of services or products that NFL may offer you via the App or our website and which you may from time to time subscribe to.

6. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

A. Personal information

(i) Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include anonymous information that does not refer to a specific user.

(ii) We may collect and process the following types of personal information in order to provide you with a safe, personal and seamless access to our App and the Services:

• personal data such as name, age, email address, phone number, physical contact information, personal description, photograph, username, password, other registration information and (depending on the service used) sometimes financial information, such as Bank Verification Number, credit card or bank account numbers;

• transactional information based on your activities on the App (such as products or service purchased, content you generate or that relates to your account), billing, and other information you may have provided in connection with your orders;

• personal information you provide to us through information pages, correspondence, chats, complaints, customer service channels, or provided to us from other social applications or services;

• additional personal information we ask you to submit as part of our verification process (for example, we may ask you to send us an identification document or utility bill to verify your address, or to answer additional questions online to help us verify your identity);

• other supplementary information obtained from third parties such as demographic and navigation data, credit check information, and additional information about you from a credit bureau, as permitted by law;

• information from your interaction with our App, services, content and advertising, including, but not limited to, device ID, device type, unique device identifiers; geo-location information, computer, operating system and connection information, statistics on page views, IP address and standard web log information;

• information stored on your device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content. This information will be accessed only with your express consent to your device’s permission on the APP. You may at anytime allow or disallow acess to information stored on your device by changing your device’s settings;

• We will collect your SMS information, but only some financial information will be screened out which helps us in identifying the various accounts that you are holding and the cash flow patterns that you have as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis to enable you to take financial facilities from the regulated financial entities and other service providers available on the platform.

• details of any of your visits to the App; including, but not limited to, traffic data, location data, weblogs and other communication data.

(iii) This information may be provided or collected by:

• filling in forms on the App;

• corresponding with us (for example, by e-mail or chat);

• registering to use the App;

• subscribing to any of our Services;

• sharing data via the App’s social media functions;

• entering a competition, promotion or survey;

• reporting an issue with the App or our Services.

(iv) To comply with the KYC policy (authenticity or effectiveness or completeness of any client's identity materials), we may dial someone in your contact list, SMS, call list or other personal information you provide to us. During the verification,we will not disclose your personal information to others.

B. Tracking and cookies

(i) We may use mobile tracking technologies and/or cookies to distinguish you from other users of the App. This helps us to improve your user experience on the App.

(ii) While you are free to decline our cookies if your browser permits, please note that doing so may interfere with your use of some of our Services.

(iii) Please also note that:

• certain features are available only through the use of cookies;

• we use cookies to help identify you and maintain your signed-in status;

• most cookies are "session cookies" meaning that they are automatically deleted from your hard drive at the end of a session;

• you may encounter cookies from third parties, which are cookies from our service providers, that we have allowed on our App to assist us with various aspects of our App operations and services;

• you may also encounter cookies from third parties on certain pages of the App that we do not control and have not authorised (for example, if you view a web page created by another user, there may be a cookie placed by that web page).

C. Use of your information

(i) Our primary purpose in collecting personal information is to provide you with access to our App and Services, and provide you with a personalized, safe and efficient experience. You agree that we may use your personal information to:

• calculate your credit limit and decide the amount that NFL may provide to you as a loan;

• provide you with access to the App, the Services and any customer support that you may request;

• resolve complaints and disputes, collect fees, and troubleshoot problems;

• prevent, detect, and investigate prohibited or illegal activities, and enforce our Terms and Conditions;

• customise, measure, and improve our contents, advertising and Services;

• inform you about our Services, deliver targeted marketing, service updates, and promotional offers based on your communication preferences;

• compare information for accuracy, and verify it with third parties;

• contact you using the telephone numbers you have provided as authorised by our Terms and Conditions (If you provide us with your phone number or emal address, you agree that we may send text messages to that phone number, or email to that email address. We will do so only in compliance with applicable laws and regulations. If you deactivate your account, you will no longer receive any texts or email from us);

• provide you with other services requested by you as described when we collected the information.

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

D. Disclosure of your information

(i) We may disclose personal information in order to respond to legal or regulatory requests, enforce our policies, or to protect the rights, property, or safety of third parties. Such information will be disclosed in accordance with applicable laws and regulations.

(ii) We may disclose your personal information to any member of our group (which means our subsidiaries, affiliates, our holding company and its subsidiaries) in order to provide joint content and services (for example, customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, sites, applications, tools and communications. These entities may use this information to send you marketing communications and you may choose to unsubscribe from their mailing list at your discretion.

(iii) We may also disclose your personal information:

• to other business entities, should we plan to merge with or be acquired by that business entity in which case personal data held by NFL about its customers may be one of the transferred assets. Should such a combination occur, the business entity will be bound by this Policy and we will endeavour to minimise any changes herein, however, we will notify you if there are any changes to our privacy policy as a result of such acquisition, merger or combination and you will be free to either decline or accept to continue engaging our Services;

• 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;

• to law enforcement agencies, governmental agencies, or other authorised third parties 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; (for example, a request relating to a civil or criminal investigation or alleged illegal activity or any other activity that may expose you or NFL to legal liability);  

• to third parties in order to enforce our Terms and Conditions and other agreements or to investigate potential breaches; 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;

• to third parties to whom you explicitly ask us to send your information (or about whom we explicitly notify you and obtain your consent before sending your information to such third parties;

• to credit bureaus. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report.

• to store information provided via cloud based in order to ensure sustainability in the event of a disaster.

(iv) Except in compliance with an order of a Court, an Arbitral Panel, a Tribunal, an investigatory panel, 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 or aggregate information about our users.

E. Storage and protection of your information

(i) The data that we collect from you may be transferred to, and stored at, a destination outside Nigeria. It may also be processed by staff operating outside Nigeria, who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests on the App or the provision of Services to you. By submitting your personal data, you agree to the collection, transfer, storage or processing of your personal data in the manner set out above. We are taking all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this Policy. Any foreign persons or entity we grant access to your data will also be bound by the terms of this Policy.

(ii) Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; 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 unauthorised access.

(iii) We have put in place appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

(iv) We expect that the personal information that you provide to us is accurate and up to date, and we will provide you with the opportunity to update your information through your account profile settings.

F. Retention of your information

We use the following criteria to determine the period for which we will keep your information:

• Our contractual obligations and rights in relation to the information involved;

• Legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time;

• Statute of limitations under applicable law(s);

• Our legitimate business purposes;

• Disputes or potential disputes.

After you have terminated your use of our Services, we may store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we may also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

G. Third Parties

Except as otherwise expressly included in this Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to other users of our App or other sites throughout the internet, different rules may apply to their use or disclosure of the information you provide to them. NFL does not control the privacy policies of third parties and will not be liable for any illegal use of your personal information by such third parties. You are, however, subject to the privacy policies of those third parties where applicable. We encourage you to ask questions and read through such third party privacy policies before you disclose your personal information to others.

H. Consent

By downloading the App and accepting our Terms and Conditions and our privacy policy, you confirm to us that we may collect, use, process, share or transmit your personal information for any of the above purposes.

I. Changes to privacy policy

Any changes to this Policy in the future will be posted on this page and, where appropriate, you will be notified when you next log onto the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of our Services. In any event, by continuing to use the App and any of our 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.

J. Information relating to children

The Services are not offered to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under any applicable laws.

We do not knowingly collect personal data from children under 18 years or under the applicable age limit in your jurisdiction (the “Age Limit”). If you are under the Age Limit, please do not use the Services, and do not provide any personal data to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to us, please contact us at dpo@newedgefinance.com to delete such data.

If we are aware that we have collected the personal data of a child under the Age Limit, we will take reasonable steps to delete the personal data as soon as practicable.

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K.  Data protection officer

We have appointed a Data Protection Officer(s) (DPO) responsible for overseeing the Company’s data protection strategy and its implementation to ensure compliance with the NDPR requirements. The DPO is knowledgeable in data privacy and protection principles and is familiar with the provisions of the NDPR.

The contact details of the Data Protection officer are as follows –

The Data Protection Officer

2a Isaac John Street, Ikeja,

Lagos, Nigeria

dpo@newedgefinance.com

The main tasks of our DPO include:

•  administering data protection policies and practices of NFL;

•  monitoring compliance with the NDPR and other data protection laws, data protection policies, awareness-raising, training, and audits;

• advice the business, management, employees and third parties who carry on processing activities of their obligations under the NDPR;

•  acts as a contact person for NFL;

•  monitor and update the implementation of the data protection policies and practices of NFL and ensure compliance amongst all employees of NFL;

•  ensure that NFL undertakes a Data Impact Assessment and curb potential risk in NFL data processing operations; and

•  maintain a Data Base of all NFL data collection and processing operations of NFL.

L. Your rights

You have the right to make a request to access and delete the personal data we hold about you, to rectify any personal data held about you that is inaccurate, the right to data portability and the right to request the suspension of the processing of your personal data. In case you wish to exercise your rights or you have other questions, comments and requests regarding this Policy, you can contact us at dpo@newedgefinance.com

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at dpo@newedgefinance.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.

M. Cross-border data transfer

Where your personal data is to be transferred to a country outside Nigeria, we will put adequate measures in place to ensure the security of such Personal Data. In particular, NFL will, among other things, conduct a detailed assessment of whether the said country is among the National Information Technology Development Agency (NITDA) White-Listed Countries with adequate data protection laws.

In case where the destination country is not among White-Listed Countries, we will only transfer Personal Data out of Nigeria on one of the following conditions:

•  Your consent has been obtained;

•  The transfer is necessary for the performance of a contract between us and you or implementation of pre-contractual measures taken at your request;

•  The transfer is necessary to conclude a contract between us and a third party in your best interest

•  The transfer is necessary for reason(s) of public interest

•  The transfer is for the establishment, exercise or defence of legal claims

•  The transfer is necessary in order to protect your vital interests of or other persons, where you are physically or legally incapable of giving consent.

Where the recipient country is not one of the White-Listed countries and none of the conditions stipulated in Section M of this Policy is met, we will engage with NITDA and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer.

We will take all necessary steps to ensure that the Personal Data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Nigeria shall be provided to you upon request.

Where the recipient country is not one of the White-Listed countries and none of the conditions stipulated in Section M of this Policy is met, we will engage with NITDA and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer.