Finnew Fintech Limited, a company established and existing in Nigeria, has created NCredit as a free application, valuing the privacy of users; anyone who uses, accesses, downloads or registers for the NCredit service on the NCredit App.

This privacy policy explains how and why NCredit collects, stores, uses and shares personal data whenever you access the NCredit App or use our services.

When you use the NCredit application or service through the NCredit App or other means, this privacy policy will apply to you. Please read this privacy policy in its entirety.

What data does NCredit collect and process?

The user hereby agrees and authorizes the lender, Finnew Fintech Limited, and its subsidiaries and affiliates, its employers, banks and certain institutions mentioned below to release any and all information required by the lender Finnew Fintech Limited, and its subsidiaries and affiliates and/or Third-party partners, such as but not limited to:

· Identity data (for example, name, last name, date and place of birth, image capture).

· The data you provide through the loan App (for example, employment information and documents, education level).

· Identity data and documents issued by the government (such as NIN, passport, driving license, voter’s card).

· Mobile device data (such as SIM, IMEI, location based on your Internet Protocol ("IP") address, application usage and history, or other device identifiers, device types).

· Read and write to external storage.

· Contact information – Ncredit will upload and transfer your contact list data (including names and phone numbers) from your mobile phone to https://appapi.ncreditapp.com. The uploaded and transferred names and phone numbers will be used to manage risks and conduct anti-fraud checks. When using the application, it will periodically send contact list data to our server. NCredit will never share your data with third parties without your permission. The collection will only be done if you agree to the authorization.

· Storage - To ensure that the user's loan account statement is safely downloaded and stored on the user's mobile phone, users need to upload appropriate files to approve and pay loans faster. This enables users to enjoy a seamless experience while using the application.

· Location - This helps to locate and verify addresses, thereby helping to make better credit risk decisions and speeding up the KYC (Know Your Customer) process.

· Camera - This helps provide users with a better and simpler way to scan or capture identity documents, etc. It allows us to automatically fill in the required data and saves a lot of time, therefore improving the user’s experience.

· Phone status - This helps to collect and monitor specific information about the phone, such as the phone’s unique device ID and user profile information in order. It is necessary because it helps to uniquely identify the user so that we can detect and prevent any unauthorized device from acting on your behalf.

· Voice call data record;

· Transaction data and financial information (such as loans, transfers, payments, loan Apps);

· Data related to your communication with NCredit (for example, your communication with NCredit via in-app chat, phone calls or other channels);

· The data you provide in connection with participating in special offers and promotions offered by NCredit (for example, promotional codes, discounts, and invitation-only groups); and

· Certain third-party data (for example, information provided to or from credit reference agencies or bureaus, external collection agencies, mobile network providers). Collectively referred to as your "information".

Purpose of processing personal information

The information we collect will be used to contact or identify you, including but not limited to:

· Verify your identity and/or other information you provide to us;

· Assess your eligibility to use our products or services;

· Provide loan services - we use and disclose your personal information to other suppliers under Finnew Fintech Limited or in cooperation with Finnew Fintech Limited, affiliates or parent companies and other suppliers to obtain payment for the services we provide.

· Detect and prevent fraud, attempted fraud and/or other illegal use of our services;

· Interfacing with credit reference or fraud prevention agencies;

· Complying with applicable laws, rules and regulations. In accordance with legal requirements, we will use and disclose your personal data, but we will restrict the use or disclosure in accordance with relevant legal requirements. When the law requires us to report abuse, neglect or domestic violence, or respond to judicial or administrative litigation, or report to law enforcement officials, we will further comply with the following requirements regarding these activities. We may disclose your personal data to a supervisory agency authorized by law. These supervision activities include audits, investigations, inspections and permits.

· Solve any problems encountered by you or other customers using the NCredit service;

· Provide customer service or support, resolve disputes and complaints;

· Manage our system, maintain service quality, and compile general usage statistics;

· Analyze and improve our services - Your personal information may be used for research purposes; the premise is that it is approved through a special review process to protect customer confidentiality. Researchers may only be able to obtain information identifying you through special review procedures or with your written consent. Your personal records can be used for data analysis to create customer demographics and trends; however, these reports are generated in a way that anonymizes customer identities.

· Send you marketing or advertising notices or other promotional offers if you have not objected to the use of your information for direct marketing purposes after proper notification;

Use of personal information

· To perform our obligations to you in accordance with any contract or agreement signed between you and us.

· To fulfill legal obligations under applicable laws.

· Relevant to our legitimate interests in the following areas: (1) to provide you with credit and/or other financial or technical products or services; (2) to operate our business; (3) to market our services to you and others; (4) to manage our system and keep our records up to date;

We will request for your consent in advance.

Safety

NCredit has adopted technical, organizational and physical measures to ensure smooth and safe loan transactions. We value your trust in providing us with your personal information, so we are working hard to use commercially acceptable methods to protect your personal information.

Not all methods of transmission or electronic storage on the Internet is 100% safe and reliable. Although we strive to store the collected information in good faith, we cannot guarantee the absolute security of the information during transmission or when stored on our system. In addition, although we try to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information. We cannot guarantee or declare that your information will not be protected, lost, misused or altered by third parties.

Changes to this privacy policy

We reserve the right to modify this privacy statement at any time in the future. After the revision, the revised privacy statement will apply to all personal data maintained by us, regardless of when it was created or received. We will keep a copy of the current privacy notice on our website and provide a copy at any time at each appointment based on your request.

This policy will take effect from November 25, 2021