Privacy Policy

This Privacy Policy is designed to help you identify the information we plan to collect from you, what the information will be used for, and with whom we may share the information.

The Privacy Policy also highlights your rights and our correlative responsibilities in relation to the information collected, and how you may contact us for additional information, clarification, or queries.

Kindly read through this policy carefully to understand our process for generating and collecting your personal information and how we plan to treat, process, use, or store the information.

This Privacy Policy applies to Fedha Limited (“we” or “us” or “our”). Fedha Limited (“Fedha or the Company”) acknowledges the importance of protecting our platforms’ visitors, users, and clients’ personal and financial information and our commitment to doing so.

This Privacy Policy highlights how we collect, handle, store, and protect personal and financial information about an identifiable, living, natural, or artificial person when:

We provide products or services to you;

• We advertise our products or services to you;
• You visit or use our website, mobile application, and other digital platforms; and/or
• We perform any other activities that form part of our ordinary or ancillary businesses.
• This Privacy Policy also contains information on instances in which we may disclose your personal information to third parties which include our service providers, credit reference agencies, collection agencies, and government agencies pursuant to an order of court or requirement of the law.

In this Privacy Policy, we may hereafter collectively or individually refer to “handling, collecting, protecting, and storing” of personal information as “processing” of personal information.

It is instructive to note that third party services, for example, websites that are linked to our website, mobile applications, or other digital platforms are not regulated by this Privacy Policy. Hence, we urge visitors to read through the privacy policies of those other websites before any personal information is provided thereat.

We have no control over, and are not responsible for the privacy policies and practices of third parties.

By accessing our website, mobile application, digital and non-digital platforms, or using our services and functions, you consent to this Privacy Policy and our procedure of processing your personal information.

Please note that your consent can be withdrawn at any time, but your withdrawal shall not render unlawful the personal information that had been processed before the notice of withdrawal was communicated.

To withdraw your consent and have your personal data deleted, kindly contact [email protected].

The Company collects personal information from identifiable, living, natural, or artificial persons. Personal Information means any information that may be used to identify a natural or artificial person or an account — this includes a name, home or office address, a photograph, an email address, banking history, marital status, phone number, age, gender, BVN, employment details (for example, name of the organization, job title and how long you have worked in the organization), country of residence, state residence, and IP address.

Personal information is typically collected when you access or browse our websites, download or use our mobile application or other digital and non-digital platforms, or upload such information on our website, mobile application, or other platforms. Also, we collect personal information for your registration on our website or mobile application, to enable you complete transactions or access special features, products, and services we provide.

Where you provide us with the Personal Information of a third party, such as account signatories, next of kin, and the details of a spouse, you are confirming you have the authority to:

• provide us with the personal information;
• consent on their behalf to allow us process the personal information you have provided; and,
• obtain privacy notices on their behalf.

We may collect or obtain your personal information from you or other people you have provided your personal information to, such as third party service providers like credit bureaus and government agencies that assist in operating our website, mobile application and other digital and non-digital platforms or who provide information to us for serving you better, ensuring effective operation, and meeting regulatory requirements.

Also, we may obtain your personal information from a third party and such third parties may include:

background check providers to verify your identity;

your employer;

your bank and other financial institution;

services and/or third-party providers we depend on to operate our platforms;

providers or anti-money laundering services and Know Your Customer (“KYC”).

The personal information provided to us is kept confidential and is used to ensure efficient and effective provision of our products or services to you. It is also used for activities that form part of our business operations.

Your personal information may be used to process your application for a product or service and to conduct due diligence ahead of providing you with the product or service.

Also, we may use your personal information:

• to respond to any request or question that you submit through our website, mobile application, or other digital platforms;
• to provide you with a more personalised experience and draw your attention to information about our products and services that may interest you or address your immediate needs;
• to provide, maintain, and notify you about new products, changes, or improvements to our existing products and services;
• to carry out an analysis of a potential market, evaluate, and improve our business and products offerings, as well as process other market statistics;
• to allow you to participate in our products features or our services when you opt to do so;
• to send marketing and non-marketing communications related to our business or the businesses of carefully selected third parties, which we may be of interest to you;
• to provide customer care and support;
• to monitor the usage of our services, so as to detect, prevent, and address any technical issues;
• to provide third parties with statistical information (this is purely for statistics and no identifiable personal information will be supplied to third parties);
• to develop and sample customers’ experience of new products and features on the service as well as to contact you for other marketing or research purposes related to existing or future products and services;
• to keep the mobile application secure;
• to comply with applicable legal or regulatory requirements;
• to comply with an order of judicial authorities or the directive of authorized regulators;
• for the purposes of performing financial accounting, invoicing, and risk analysis purposes. Also for prudent operational management (including credit and risk management, audit, training, and similar administrative purposes);
• for the purposes of engaging with our professional advisors, such as lawyers, accountants, consultants, intermediaries, brokers and other individuals and entities that partner with us as necessary for providing products and services to you; and,
• to protect our rights and those of our customers.

We are required to state in this Privacy Policy our legal basis for processing personal information.

The legal grounds for processing the personal information are:

• for regulatory and/or legal obligations to keep records of business transactions and, when requested, provide the processed information to a public body or law enforcement agency;
• to take pre-contractual steps at your request and perform contractual obligations owed to you;
• it is necessary for our legitimate interests and operations and does not unduly affect your interests or fundamental rights and freedoms;
• we have obtained your prior consent (where necessary).

To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because:

you have given us your explicit consent to process that information;

• the processing is necessary for reasons of substantial public interest on the basis of applicable law (for example, where we are required by law or regulatory requirements to process that information in order to ensure we meet our KYC and ‘anti money laundering’ obligations); and/or
• the processing is necessary for the establishment, exercise, or defense of legal claims.
• The Nigeria Data Protection Regulation of 2019 is the law that governs how your personal information is being processed.

The personal information provided to us is kept confidential and will not be shared or disclosed except:

• the law requires that the processed information be shared;
• by the order of a court or tribunal;
• your interest or our interest requires us to disclose the processed information;
• you instructed us to disclose your personal information;
• we have a public duty to share the information.

By giving your consent to this Privacy Policy, you agree that we may share your personal information with the following:

• our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors, insofar as reasonably necessary for the purposes set out in this policy.
• our consultants that provide us services, including accountants, platform providers, risk assessors, investment experts, marketers, financial advisors, lawyers, and IT systems providers.
• to a potential buyer, transferee, merger partner, or seller and their advisers in connection with an actual or potential transfer or merger of part or all of Fedha’s right and interest in the business.
• to credit bureau agencies or other private or government organizations that detect fraud and criminal activity.

For the avoidance of doubt, we will not disclose your personal information to any external organisations, unless you request us do so, we are required to do so by law, or where it is necessary to for the performance of our agreement with you.

We retain and store personal information for the duration that is required for the purpose for which you have given it and as legally required. Your information is destroyed or anonymised once they are no longer required for the purpose they were collected and there exists no statutory requirement to keep them. Notwithstanding the other provisions of this section, we will retain documents and materials (including electronic documents and materials) containing personal information:

• to the extent that we are required to do so by law;
• if we believe that the documents and materials may be relevant to any ongoing or prospective legal proceedings; and
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of crime/fraud prevention and reducing or investigating crime).

We operate a system that protects the Personal Information we receive from both authorized and unauthorized usage.

We maintain electronic, procedural, and physical measures to safeguard your personal information and also to ensure your personal information is up to date and accurate to the extent provided by the end user.

Such measures include:

• Restricting access to your personal information to a “need to know basis”;
• Regular training of our staff and the education of our consultants on our privacy policy obligations;
• Ensuring high standards of technical security measures to protect all information electronically sent to us, through methods such as encryption and firewalls;
• Maintaining such physical security as is necessary in our premises; and,
• Real time monitoring and maintaining industry-standard cyber security defence.

By providing us with your personal information, you consent to the mode of transferring, storing, and processing of your personal information adopted by our Company. We will ensure that your personal information is securely treated in line with our privacy policy.

The personal information we collect and process will be stored in secure servers on the cloud.

Your personal information shall be deleted and/or anonymized in the event of any of the following:

• In compliance with National Information Technology Development Agency or any other lawful directive;
• Where you withdraw your consent and object to us processing your information;
• When we no longer require your information for the purposes for which it was collected or processed; and,
• The personal information was unlawfully given or processed in the first instance.

Under this Privacy Policy, you have the following rights:

• To request a copy of the personal information in our custody;
• To request that the personal information you provided be updated (based on further information supplied by you) or corrected;
• To request that the personal information we have in our custody be deleted or anonymized;
• To restrict our use of your personal information to a particular product or service;
• To object to the processing of your personal information;
• To withdraw your consent previously given and object to us processing your personal information.

We may process additional information, like your IP address, when our website and mobile application or other platform is visited.

We use the information to monitor the use of our website and collect data that assists us to add value to our products and services.

Please note that this information does not include the personal information of any individual.

Please be aware that our mobile application and website may be connected to third party websites.

However, even where we take necessary steps to affiliate ourselves with third-party services that have high privacy standards, we shall not be responsible for their content, privacy procedure, and/or security statement.

Kindly read carefully through their privacy procedure and security statements as provided on their websites before providing any personal information on their platforms.

Fedha, its directors, partners, agents, employees, affiliates shall not be liable for any indirect, direct, special, incidental, consequential or punitive damages arising from:

• access or inability to access or use our website or any of our products or services;
• unauthorized access, use, or alteration of your transmissions whether based on tort (including negligence), contract, warranty or any other legal theory, whether or not we are aware of the possibility of such damage, and even if a remedy is found to have failed as regards purpose;
• any content obtained from our website or application or other platforms; and,
• any conduct or content of any third party on our service.

Please note that our privacy statement may change.

Our Privacy Policy may, from time to time, be updated. The latest version of our privacy statement will replace the earlier versions, unless it is otherwise stated.

We may notify you of changes to our privacy policy by email or through other notification systems on our digital platforms.

We shall endeavour to settle amicably any dispute arising in connection with this Privacy Policy.

Where such disputes, differences or claims are not settled amicably within 21 (Twenty One) days, the dispute shall be referred to the Lagos State Multi-Door Court House (“LMDC”) for mediation.

Where mediation is not concluded within 3 (Three) months, Parties reserve the right to seek redress in appropriate Court in the Federal Republic of Nigeria.

Please note that each party shall bear its own costs and would be liable to contribute the same amount in respect of fees to be paid to the Mediator.