1. 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.

      1. Personal information

    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 verificationwe 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

    • and any other services anticipated for the future.

    (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 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.