Current as of 10th May, 2022
By accessing our website, you are agreeing to be bound by these terms of service, and agree that you are responsible for compliance with any applicable local laws.
This Data Protection Policy in conjunction with our Privacy Policy (https://creditchek.africa/privacy) expressed Creditchek which hereinafter may be referred to as (“our” “we” or “the Company”) assurance and commitment to treating the information of customers, stakeholders, partners, and other interested parties (“You or Your”) with the utmost care and confidentiality by the Nigeria Data Protection Regulations and each jurisdiction which data subject who we process data.
With the provisions of this data protection policy and our privacy policy, we acknowledge that we gather, store, and handle data fairly, transparently, and with utmost duty of care and respect towards individual rights
This document is prepared in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Nigerian Data Protection Regulation (NDPR). It sets out how CreditChek Technologies Nigeria Limited (CreditChek) applies and complies with the principles of the regulations in processing the personal data of individuals, clients, vendors, and even third parties that interact with CreditChek.
For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed in compliance with the GDPR/NDPR.
As part of CreditChek’s operation, we often obtain and process information which includes names, addresses, phone numbers, Emails, bank verification number, national identity number, loan/credit history, bank account credit and debit data. We collect this information securely and transparently and only with your full consent/cooperation and knowledge with an aim to enable assess and determine your credit worthiness.
To ensure the protection of this information, we apply the following rules.
To exercise the provisions of data protection regulations and show our commitment to ensure our compliant and adhere to the provisions, We:
2.1 Roles and responsibilities:
Data Protection Officer
All Employees/Staff who interact with personal data
We obtain your personal data when you use our service through the registration process. In the process of signing up, we request data such as name, phone number, address, Email, Company name, Designation, and Country. Through a third-party source, in the process of funding your wallet, you will be directed to our payment institution platform where you will be required to input your card details for such funding. Please note that the data at this stage is not stored on the Creditchek platform but the third party. Likewise, while using our services, you may be required to fill in your details and/or your customer’s details during the use of our Phone book, Teams, Group, or Direct SMS services. In addition, when interacting with our customer service, you may be required to provide us with more personal data to provide quality services to you.
3.1 Who We Are
CreditChek Technologies Nigeria Limited (CreditChek) uses structured, user-permissioned data from multiple sources to create powerful credit and financial data verification services that empower FinTech’s, banks, microfinance institutions, retail businesses and mobile money operators to build better financial products for the underserved. CreditChek is well positioned to provide the much-needed solutions that will drive financial inclusion across various sectors and industries in the region, and beyond.
The personal data we would collect and process, depending on the processing requirement are under the following categories:
Personal Data Type
Sources
General
Ordinary personal data may include personal identification details such as name and address, customer relationships, personal finances, tax-related matters, debts, work-related circumstances, family circumstances, residence, car, qualifications, applications, CV, date of employment, position, area of work, work phone, key data: name, address, date of birth, IP address or other similar non-sensitive information.
Information about national identification numbers
Identification and verification numbers as the BVN, NIN and related are used to validate the trueness and liveness of individuals being assessed for credit worthiness. This can be from the financial institution, credit organisation, and government agencies.
Cookies
We use cookies to improve your browsing experience on our website. By browsing on our website, you consent to our use of cookies in accordance with our privacy/cookie policy.
Ways in which we used the personal data provided to us include processing or delivering our services, notifying you of the status of the services, sending marketing or campaign affiliates to which you opt-in.
CreditChek ensures that the personal data collected and processed is necessary for the purpose of collection, and CreditChek shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:
Purpose of processing
Lawful basis of processing
Identity verification and maintenance of records
Compliance with a legal obligation in which CreditChek is subject to (KYC/KYB).
Financial transactional analytics
Required by a credit service organisation to assess the credit worthiness of an applying borrower.
Credit history assessment
Required by a credit service organisation to assess the credit worthiness of an applying borrower.
Onboarding staff members
Contract.
Where Legitimate Interest is considered the legal basis for processing personal data, CreditChek shall follow the steps below in carrying out a Legitimate Interest Assessment.
1. Determine the Purpose for Processing
In carrying out the purpose test, CreditChek must establish the exact reason for the processing and how it benefits the organisation. Answers to the following shall be provided to determine the exact purpose for processing:
2. Determine the Necessity of the Processing
CreditChek must establish why the processing must take place, how the processing relates to the expected benefits, and any other alternatives and why they were not considered.
3. Balance the identified interest with the Privacy Interest of the Data Subjects
The following questions will be addressed under the balance test:
CreditChek records this information in line with this policy, data protection impact assessment, and data inventory.
We may share your data with our partners or suppliers to provide services to you. Such data may include your name, phone number, email address, and other general related data. We may also share your data with companies or organisations that we engage to provide services to us for the furtherance of your transaction or direct you to a third-party website that may provide services for you directly and/or on our behalf. An example is the funding of your wallet stage.
THE PRIVACY POLICIES OF THESE THIRD-PARTY SITES MAY BE DIFFERENT FROM OUR DATA PROTECTION AND PRIVACY POLICY. THUS, WILL GOVERN ANY TRANSACTIONS AND SERVICES PERFORMED ON THAT SITE. CREDITCHEK AND SUCH COMPANIES ARE EACH INDEPENDENT DATA CONTROLLERS AND NOT JOINT DATA CONTROLLERS. Hence, you are advised to read and consent to such third-party site data protection and privacy policy.
Notwithstanding the provision of this clause, Creditchek does not sell or trade customer personal data to anyone. We only use it to render our services to you.
CreditChek requires your explicit consent to process collected personal data. And by consenting to this privacy policy, you are giving us the permission to use/process your personal data specifically for the purpose identified before collection.
If, for any reason, CreditChek is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.
You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the CreditChek Withdrawal of Consent Procedure.
We secure your data by using a database with limited access and a secure server that encrypts all the data we collect. Hence protecting it from unauthorised third parties. We as well use multiple security control systems in layers to prevent access to information on our system.
7.1 Disclosure
CreditChek will not pass on your personal data to third parties without first obtaining your consent.
Where there is a need for a third party to process the personal data of data subjects, CreditChek will enter into a Data Processing Agreement with the third party and be satisfied that the third party has adequate measures in place to protect the data against accidental or unauthorised access, use, disclosure, loss, or destruction.
In a case where the disclosure is to third parties outside the jurisdiction of the GDPR and NDPR, CreditChek will ensure that the third party meets the core regulatory standards prior to the transfer. This may include transferring the personal data to the third party where CreditChek has satisfied that:
7.2 Retention of Records
In compliance with the GDPR/NDPR data retention policy, CreditChek will process your personal data for about six (6) years and will retain the personal data for ten (10) years after processing.
This retention period has been established to enable us to use the personal data for the necessary legitimate purposes identified, in full compliance with the legal and regulatory requirements. When we no longer need to use your personal information, we will delete it from our systems and records, and/or take steps to encrypt/anonymise it to protect your identity.
It is the responsibility of you as Creditchek customer to ensure that you comply and continue to comply with Applicable Data Protection Laws and Regulation in your use of our services and in processing personal data. In addition, you will be responsible for the right to transfer, share and receive the consent of data subjects that you share with us to provide our service or usage of our service.
By using our service, you hereby undersigned and agree as follow:
You are complying and will continue to comply with applicable Data Protection Laws and Regulations that you processed through your use of our service.
Hereby indemnify Creditchek of any and/all liabilities, claims, legal actions, losses, and damages because of data violation and/or you are breaching any data protection laws and regulations.
You will not intentionally collect or process any special categories of Personal Data unless Creditchek includes such types of data in the content submitted to you
Taking into account the nature of processing and the information available to you, You shall provide Creditchek, insofar as this is possible and at Creditchek’s written request, with all information required for Creditchek to comply with statutory obligations under Applicable Data Protection Law (in particular, the obligations necessary to ensure the Creditchek’s compliance with security of processing, personal data breach notification, data protection impact assessment, and prior consultations with supervisory authorities), and will assist Creditchek, insofar as reasonable, in meeting these statutory obligations.
9.1 Data Subject Rights
Data subjects, according to the provision of the GDPR/NDPR, have certain rights. At any point while CreditChek are in possession of or processing your personal data, you, the data subject, have the right to:
All the above requests will be forwarded should there be a third party involved in the processing of your personal data.
You have the reserved right to decline the request of providing your personal information when requested by Creditchek or Creditchek’s authorised representatives. You also have the right to withdraw given consent to our data protection policy and privacy policy Please contact us at [email protected] if you wish to exercise any of your rights. It is however noteworthy to mention that certain services or all services may be unavailable to you afterward.
For more information on how we use your personal data and why, please visit https://creditchek.africa/privacy-policy