1. Introduction/Scope

This document is prepared in accordance with the provisions of the Nigeria Data Protection Act 2023 (NDPA). It sets out how Afriquid Finance Limited applies and complies with the data privacy principles in processing the personal data of customers, staff, vendors, visitors, and even third parties that interact with us.

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 NDPA.

This privacy policy describes why and how we collect and use personal information about our customers, clients, vendors, and visitors (data subjects). It also highlights with whom we might share Personal Information and how long we keep such information. It also makes data subjects aware of their rights under the Nigeria Data Protection Act 2023.

2. Roles/Responsibilities

Afriquid Finance Limited's Data Protection Officer (DPO) is responsible for ensuring that this document is correct and up-to-date. The DPO also ensures that data subjects are duly notified prior to the collection and processing of their personal data, including data collected via the Afriquid Finance Limited's website. All Afriquid Finance Limited employees/staff who interact with personal data must also ensure to follow the provisions in this policy document.

3. Policy Statement

Afriquid Finance Limited is committed to protecting the privacy and security of data subjects' personal data. We are responsible for determining how we hold and use personal information about our data subjects. According to the Nigeria Data Protection Act (NDPA), Afriquid Finance Limited is required to notify data subjects of the information contained in this document.

• 3.1 About Afriquid Finance Limited

  Afriquid Finance Limited is incorporated under the laws of the Federal Republic of Nigeria, with our registered office at 11C Oba Akinjobi street, GRA, Ikeja, Lagos, Nigeria. We provide adapted retail financial services to individuals and salary earners in Nigeria.

  Afriquid Finance Limited is a reputable technology-driven financial institution that is recognized for innovation, superior performance, and creation of premium value for all stakeholders.

  We are driven by a culture of excellence and strict adherence to national and global best practices, combining vision, skillful financial service expertise, and cutting-edge technology to create products and services that anticipate and meet customers' expectations while enabling individuals and businesses to thrive and grow.

• 3.2 What Personal Data Do We Need?

  The personal data we collect and process, depending on the particular processing requirement, are under the following categories:

• Data Type	Description of Data
  Identity Data	Full Name, maiden name, marital status, title, NIN, date of birth, gender, address and employment history, and citizenship.
  Contact Data	Address, Email Address and Telephone Numbers Information received during your contact with face-to-face meetings, phone calls, emails, letters and SMS
  Financial Data	Bank account information and bank statements, Bank verification Number (BVN), your income and outgoings, your financial position, status, and credit history, debit or credit card information and account number.
  Transaction Data	Information regarding the products and services you may have benefited from by using Afriquid Finance Limited, transactional information including in respect of products which you purchase. Location data of transactions where you may use your debit card
  Technical Data	Internet protocol (IP) address, your login data, details of your browser and operating system, time zone setting and location, browser plug-in types and versions, platforms and other technology on the devices you use to access this website
  Profile Data	Includes your username and password
  Job Application Data	Data submitted throughout the recruitment process eg: name, email address. Any personal information you provide to Afriquid Finance Limited as part of the recruitment process.
  Usage Data	Includes information about how you use our website, products and services
  Marketing and Communications Data	Information about your communications with us. Your preferences in receiving marketing e-mails from us and consents you have given us

  Where the personal data we need to collect may fall under a special category of sensitive personal data, the lawful basis of processing will be the explicit consent of the individual, or where applicable, compliance with a legal obligation, or for legal proceedings/advice.

4. Why We Need the Data

Afriquid Finance Limited ensures that the personal data collected and processed is necessary for the purpose of collection and shall not collect or process more data than is reasonably required for a particular processing activity.

5. Legal Grounds for Processing

Afriquid Finance Limited identifies, establishes, defines, and documents the specific purpose of processing and the legal basis for processing personal data (including any special categories of personal data processed) before any processing operation takes place under:

• - Consent obtained from the data subject;

• - Performance of a contract where the data subject is a party;

• - Legal obligation that we are required to meet;

• - Protection of the vital interests of the data subject, including the protection of rights and freedom of the Data Subject;

• - Official authority to carry out the processing that is in the public interest;

• - National law, such as biometric data.

6. Processing of Personal Data Based on Consent

Where applicable, Afriquid Finance Limited will require the explicit consent of customers, visitors, and other relevant stakeholders to process collected personal data. Website visitors are expected to read and understand the website privacy notice and agree to the website’s terms of use. By consenting to the privacy policy, data subjects are giving Afriquid Finance

Limited the permission to use/process their personal data specifically for the purpose identified before collection.

If any data subject (customer, client, visitor, vendor, staff, or third party) does not agree to Afriquid Finance Limited collecting and processing their personal data, such individuals are not allowed to enjoy service(s) where applicable.

• 6.1 Withdrawal of Consent

  Irrespective of initial consent given, an individual can withdraw their consent at any time by making a withdrawal of consent request.

7. Use of Cookies

The website uses cookies provided by trusted third parties, such as Google Analytics, to help us understand and improve users' experience on the website.

8. Disclosure to Third Parties

Asides situations where we may be required to disclose personal data of individuals in accordance with a legal obligation, Afriquid Finance Limited will not pass on its data subjects' personal data to third parties without obtaining consent.

• Cross-Border Transfers

  Afriquid Finance Limited may engage third parties abroad (such as banks, contractors, government-authorised agencies, etc.) that will receive personal data for certain purpose(s) as part of the Society's processing activities and process them on the Society's behalf.

9. Retention of Records

Afriquid Finance Limited stores and retains personal information in compliance with NDPA’s guidelines on data retention.

10. Data Subject Rights

Data subjects have various rights, including requesting a copy of the information held about them and asking for data correction, erasure, or restriction of processing under certain conditions.

11. Complaints

If a vendor/contractor, customer, or staff wishes to make a complaint about how Afriquid Finance Limited handles their personal data, they have the right to lodge a complaint with the supervisory authority and Afriquid Finance Limited Data Protection Officer.