This
Privacy Policy was last updated on the 01-12-2022
This
privacy policy (the “Policy”) together with
our Terms and Conditions as set out on the Arich Loan Application
(the “APP”) and any additional terms and conditions apply to your
use of the Services (as defined hereafter) provided by Arich Loan
Nig. Limited (“Arich loans ”, “we” or “us”).
The
Products Arich covered by this policy are Arich: Customer, Agent and
Business.
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.
By
clicking on the button labelled “Sign Up” below and proceeding
to use the Service or access any of other services through our
Service, 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.
We
may amend this Policy at any time by publishing the amended terms on
APP. All amended terms shall automatically become effective on the
day that they are published. Additionally, we will notify you of any
substantive or material change in this Privacy Policy by one of
following means: updating this web page, sending push notifications,
e-mails or letters, by phone or by publishing announcements on our
website. For the purposes of this Policy, the term “Service”
shall be defined as any form of services or products that we may
offer you via our APP or our website and which you may from time to
time subscribe to.
Please
read the following carefully to understand our views and practices
regarding your personal information and how we will treat it.
This
collection and processing of your personal data is in accordance with
The National Information Technology development agency Act 2007, Data
protection Regulation 2019 and the Provisions of Section 5 part 1 and
2 of National information systems and National security standards and
guidelines
(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 access to our App and the
Services the Information we collect may include but not limited to
the following:
• 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 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);
•
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;
• 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 the following but
not limited to:
• 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 local 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 leak 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 the 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 that 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 our Services, and provide you with a
smooth and efficient experience. You agree that we may use your
personal information to:
• evaluate
your credit limit;
• 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 authorized by
our Terms and Conditions;
• provide
you with other services requested by you as described when we collect
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 protect anyone's
rights, property, or safety. 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 unsubscribe from their mailing
list.
(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 Arich
about its customers may be one of the transferred assets. Should such
a combination occur, we will endeavour to minimise the changes to
this Policy, however, we will notify you if there are changes to our
privacy policy as a result of such acquisition, merger or
combination;
• 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 Arich 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
cloud storage providers to store the information you provide and for
disaster recovery services, as well as for the performance of any
contract we have entered into with you;
(iv)
Save 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 fulfilment 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.
(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 a
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 unauthorized
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 can store your
information in an aggregated and anonymized format. Notwithstanding
the foregoing, we can 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. Arich
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 before you disclose your personal information to others.
H.
Consent
By
accessing 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 we may make to this Policy in the future will be posted on
this page and, where appropriate, notified to you 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 the
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 13 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 support@myarich.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.
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
The
main tasks of our DPO include:
•
administering
data protection policies and practices of Rockit;
•
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.
