1. CONSENT

By downloading the Fewchore Mobile App (“the App"), visiting our website at Fewchore Mobile, ticking the box saying, “I agree to the Terms and Conditions”, or performing any other activity that form part of our business (digitally or non-digitally), you confirm that you have read, understood and accepted the terms of this Privacy Policy set out hereunder. You also consent to the following:

• That we can provide materials and other information about your legal rights and duties to you electronically.
  
• That we are authorized to share, receive and use data/information collected from your transaction with other affiliated third parties.
  
• That your electronic signature on agreements and documents has the same effect as if you signed them using ink on paper or any other physical means.
  
• That we can send all important communications, billing statements and demand notes and reminders to you electronically via our app or to an email address that you provide to us. When we send you such information/data electronically and/or make it available online as indicated above, that shall have the same meaning and effect as if we provided said information/data to you physically.
  
• For the avoidance of doubt, approval of the credit facility under this Agreement is conditional upon the validation of your bank verification number (BVN) and verification of your debit card. This offer will be rescinded and the approval for the credit facility will not be successful if the BVN validation and other verification checks are unsatisfactory.
  

Such consent can be withdrawn at any time, provided always that such withdrawal will not affect the legality and binding effect of the processing of your personal information before the consent given was withdrawn.

This Privacy Policy together with our Terms and Conditions and any additional terms applies to your use of the System and the Service.

2. LINKED WEBSITES

Other websites that may be linked to us are not governed by this Privacy Policy. You re advised to review the privacy policies on each of the websites before disclosing any personal information.

This Privacy Policy includes the following matters:

• Definition
  
• Personal Information which we collect
  
• The use of Personal Information which we collect
  
• Sharing of Personal Information which we collect
  
• Cross-border transfers of Personal Information
  
• Retention of Personal Information
  
• Access and update/correction of Personal Information
  
• Where we store your Personal Information
  
• Security of your Personal Information
  
• Changes to this Privacy Policy
  
• Language
  
• Acknowledgement and consent
  
• Marketing and promotional material
  
• Third party websites
  
• Limitation of liability
  
• How to contact us
  

3. DEFINITION

Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meanings ascribed to them in our Terms and Conditions (as applicable).

• “Applicable Law” means all national and international legislations, regulations, circulars, guidelines that govern this Privacy Policy or any activities done by us in the processing of your personal information. It shall include, without limitations, the Nigeria Data Protection Regulation, 2019, the Money Laundering (Prevention and Prohibition) Act, 2022 etc.
• “Processing” means the collecting, handling, protecting, and storing of your personal information. It shall include the need and manner of disclosure of your personal information to third parties (including without limitation, our service providers and credit rating agencies).
• “You” means all users of the App, including persons that have downloaded the app, visited the website, or performed any activity that forms part of our business.

4. PERSONAL INFORMATION WHICH WE COLLECT

We collect certain Personal Information about you in various forms. The Personal Information which we collect may be provided by you directly (for example, when you open an Account to use the Service via the App, or you otherwise provide Personal Information to us in a form on our app or website) or by third parties (including but not limited to your employer, providers of “Know-Your-Client” and anti-money laundering services, background check providers, your banks and financial institutions, credit rating and reference providers etc.), or collected by corresponding with us via email or chat, or be collected automatically when you use the App. We may collect information in various forms and for various purposes (including purposes permitted under Applicable Law).

Information obtained from you or from your Mobile Device directly:

• When you register and create an Account with us using the App, you have to provide certain Personal Information, including (without limitation) your name, age, date of birth, gender, photo, physical home address, e-mail address, working information, emergency contact, your phone number, country of residence, employment details (e.g. the name, address and contact details of the organization you work for, your job title, your salary details etc.), financial and credit information (including your bank account details bank verification number, and bank statements where applicable) and an Account ID and/or password amongst others that you will use to access the App after registration.
• When you use the App, you must provide such relevant information as may reasonably be required by us for the App to work. For example, when a payment is made through the electronic money facility within the App, you will provide information relating to the payment, such as the type of payment card used, the name of the issuer of that payment card, the name of the account holder for that payment card, the name of the beneficiary of the payment, the account number of the beneficiary of the payment, the number of that payment card, and the amount of money paid amongst others .

Information collected whenever you use the App:

• Whenever you use the App, we may collect certain technical data concerning your usage such as, internet protocol (IP) address, information as webpages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, and also information regarding the manufacturer, model and operating system of the device that you use to access the App.
• Whenever you use the App, certain information may also be collected on an automated basis using cookies. Cookies are small application files stored on your computer or Mobile Device. We use cookies to track user activity to enhance user interface and experience. Most Mobile Devices and internet browsers support the use of cookies; but you may adjust the settings on your mobile device or internet browser to reject several types of certain cookies or certain specific cookies. Your Mobile Device and/or browser would also enable to you to delete at any time whatever cookies have previously been stored. However, doing so may affect the functionalities available on the App or our Website.
  
• You agree to provide the information listed in Clauses 4.1.1. and 4.1.2. above because they are mandatory requirements of the Central Bank of Nigeria, the regulator of our business.
  
• Meanwhile, you will be required to provide technical information to us while using the App, including the type of Mobile Device you use, a unique device identifier (for example, your mobile device’s IMEI number, the MAC address of your Mobile Device’s wireless network interface, or the mobile phone number used by your Mobile Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
  

Collection of Location

We collect your geo-location information when the App is running in the foreground. We endeavor to cease collection of your geo-location information when the App is in the background, but such information may still be collected unintentionally. You can always choose to disable the geo-location tracking information on your Mobile Device temporarily. However, this may affect the functionalities available on the App.

Collection of Financial SMS Information

• We don’t collect or store your personal SMS from your inbox.
• We only collect financial SMS sent by 6-digit alphanumeric senders from your inbox 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.
  
• While using the app, it periodically sends the financial SMS information to our affiliate server and to us.
  
• We collect SMS information only after obtaining your additional explicit consent.
  
• The SMS information will be uploaded to Fewchore Mobile. We will delete the SMS information after we have determined your risk profile.
  

Collection of Installed Applications

We collect a list of the installed applications metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers only for the purpose of this service and undertake not to disclose the information to a third party without your prior consent.

Storage

We require the storage information permission that allows the App to enable you to upload photos and/or documents to complete the application form during your loan application journey.

Camera

We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.

Media, Photos and Files

We require the media, photos, and files permission that allows the App to enable you to upload photos or documents to complete the application form during your loan application journey.

Calendar Information

• We require calendar information so that you can set up a loan due date memo in the app after the loan, which will remind you to repay your loan on time.
  
• The calendar information will be uploaded to Fewchore Mobile. We will delete the calendar information after we have determined your risk profile.
  

Information collected from Third Parties

Due to the nature of the Services which we provide, we are required to work with a number of third parties (including Credit Reference Bureaus, Banks, Mobile Network Providers, collection agencies, our agents, vendors, suppliers, contractors, partners and any others who provide services to us, perform functions on our behalf, or whom we collaborate with) and we may receive information about you from them. In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be), provided that we have taken reasonable steps to ensure that such third parties would undertake to us to obtain your consent for the disclosure of your Personal Information to us in line with this Privacy Policy and Applicable Law.

Information about Third Parties you provide to us

You may provide us with Personal Information relating to other third-party individuals (such as Personal Information relating to your spouse, family members, friends and emergency contact). You will of course need their consent to do so–see Section 12 “Acknowledgement and Consent”, below, for further information.