twaleloan (Originally named SwiFund) values your Personal Data and we are committed to protecting your privacy whenever you interact with us. Please read this Privacy Notice (Notice) to understand our policies, processes and procedures regarding the processing of your personal data.

By this Notice, We will explain to you how your Personal Data is collected, used, managed and transferred by twaleloan (Originally named SwiFund) and also explain how you can update your Personal Data with us and exercise your rights in respect of the Personal Data.

When you sign up and use twaleloan (Originally named SwiFund) (via our website or Google Play Store), you accept the terms described within this agreement, and consequently you are enjoined to carefully read the terms and conditions, before agreeing to them.

INFORMATION WHICH MAY BE COLLECTED FROM YOU

Customer information
1

To use the twaleloan (Originally named SwiFund) Services, you must provide personal information via our registration process, account upgrade or profile forms.

These information includes, but are not limited to:

Full name, e-mail address, phone number, twaleloan (Originally named SwiFund) PIN, and address;

For some services we may also collect Bank Verification Number (BVN/NIN) and photograph (where applicable);

Additional information may be requested to participate in social media functions on our site, promotions or surveys and when you contact us to report a problem on our site.

If you communicate with our Customer Services team via e-mail, Live Chat or telephone, your conversations may be recorded and stored for training and record keeping purposes (in line with the provisions of the relevant laws and regulations). These information are used to measure and improve our Service quality.

Device information
2

The following information that may be collected from you automatically when you use the twaleloan (Originally named SwiFund) mobile app, may include but are not limited to:

Call Records

In order to provide better loan services and ensure that you are a genuine participant in loan transactions, twaleloan (Originally named SwiFund) will require you to authorize access to call records and verify your OTP records through call records, and we will upload this information to the server (https://api.twaleloan.com) for assessment.

GPS

twaleloan (Originally named SwiFund) requires your authorization to access your GPS to ensure that you are currently located in Nigeria, eliminate your risks, and upload your location information to the server (https://api.twaleloan.com).

Installed Application List

twaleloan (Originally named SwiFund) needs to access and check the list of applications installed on your device to ensure that you have not installed any tools or applications that can change the information you have submitted, and the data obtained will be uploaded to the server (https://api.twaleloan.com).

Camera

twaleloan (Originally named SwiFund) requires your authorization to access your camera to take your picture during credit approval process to ensure that you are a genuine participant in loan transactions, in order to protect your financial security. We will upload these photos to the server (https://api.twaleloan.com).

Calendar

twaleloan (Originally named SwiFund) needs your authorization to access your calendar, read your time, location, themes and other contents, to assess your financial situation, and to help you create repayment calendar reminders. We will upload this information to the server (https://api.twaleloan.com).

Device Information

twaleloan (Originally named SwiFund) needs your device information, including device model, IP address, and access time, to assess your financial risk and upload data to the server(https://api.twaleloan.com).

Contact Information

twaleloan (Originally named SwiFund) will require you to agree to us accessing your contact list to eliminate your financial fraud risks, and the data obtained will be uploaded to the server (https://api.twaleloan.com).

Other Information

twaleloan (Originally named SwiFund) will collect and manage your other personal information, such as your name, email, BVN, phone number, NIN, etc., to ensure your successful access to our applications and services.

twaleloan (Originally named SwiFund) encrypts all personal information uploaded and stored on our servers. Unless you give us explicit permission, we will not share your data with third parties, and we will not use your personal information unless there are special circumstances.

TRACKING AND COOKIES

A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns.

twaleloan (Originally named SwiFund) uses cookies to help it identify and track visitors, their usage of the twaleloan (Originally named SwiFund) website, and their website access preferences. twaleloan (Originally named SwiFund)’s visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the websites, or decline the option of using cookies on their first visit. However, our website may not function properly without the aid of these cookies.

Google Advertising ID

We need the data of this Google Advertising ID and show you personalised ads based on the Google Advertising ID.

Google Advertising ID is an unknown identifier that is provided by Google to show more targeted ads on mobile devices. We will only collect and use it with the explicit authorization and consent of the user. Besides, it is not associated with the user's personal information. We promise to protect your privacy and security of data.

USING THIRD-PARTIES

twaleloan (Originally named SwiFund) integrates with the 3rd parties to provide you with an end to end Service. These providers follow the practices outlined in this Policy.

twaleloan (Originally named SwiFund)’s service providers are used to:

Validate information about you. This may include credit rating agencies, mobile network providers, BVN/NIN validation services, and these services will be triggered depending on the financial services you are accessing.

Process your payments, including banking, card or merchant payments

When we work with service providers to process payments, we may share information with the provider which would include:

Contact information (mobile number, e-mail address )

Account information

Payment details (amount, transaction type, rules and authorization information)

We use this information to confirm to the vendor that you are a twaleloan (Originally named SwiFund) customer and that the vendor should process the payment on your behalf.

twaleloan (Originally named SwiFund) reserves the right to change service providers without notifying our customers.

When twaleloan (Originally named SwiFund) provides access to additional services, you will be responsible for agreeing to the Terms and Conditions for these 3rd parties. We can provide no guarantee or warranty for the way in which these 3rd parties use your information.

HOW YOUR INFORMATION MAY BE USED

To process payments on twaleloan (Originally named SwiFund), we need to share some of your personal information with the person or company with whom you are transacting.

These information may include:

Contact information (mobile number, e-mail address, personal photo)

Payment information (card details, banking information)

We may also need to collect and process the following types of personal information in order to provide you with access to our App and the Services:

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 the 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);

Other supplemental 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.

IDENTITY INFORMATION

We collect and store personal information about you to comply with the relevant financial regulations, and also in compliance with the relevant laws and regulations governing the industry. Apart from the circumstance of complying with a Court Order, Arbitrary Panel, Tribunal, Regulatory Directive or Order 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 aggregate information.

For example, when we use a 3rd party service, with your consent, we may share your information in order to offer the service or improve the experience of our customers.

WHEN YOUR INFORMATION MAY BE DISCLOSED

Your information may be shared in the following cases:

To fulfil a request from the regulator or government entity having appropriate authority

To fulfil other legal obligations such as a court order

For regulatory reporting purposes

To assist in an investigation which involves suspicion of fraud or wrongdoing

under the explicit instruction of the customer

WHERE YOUR PERSONAL INFORMATION IS STORED

twaleloan (Originally named SwiFund) is entirely committed to protecting the information we collect from you. We maintain appropriate administrative, technical and physical safeguards (i.e. firewalls, data encryption, competent security guards, etc).  These processes are in place to prevent accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of your information.

twaleloan (Originally named SwiFund) is required to retain the details of transactions or payments you make via twaleloan (Originally named SwiFund) after the transaction is completed. We will store these transactions for the required period under the financial regulations of this jurisdiction and in conformity with the relevant laws and regulations governing the industry.

YOUR RESPONSIBILITIES

You are responsible for the protection of your password or PIN in its entirety as communicated in our Terms and Conditions. You must not share your twaleloan (Originally named SwiFund) password or PIN with anyone.

We will never request for your passwords via email or SMS or any other means. In the event you share your password with a third party, you will be held responsible for the consequences. If you believe your password or PIN has been compromised, please change it immediately and contact us.

YOUR RIGHTS

We will use your data for the purposes of collecting statistics relating to our user base and may disclose such information to any third party for such purposes, while ensuring that the information provided by you remains anonymous.

Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information.

You have the right to request the deletion of data stored on our APP concerning your personal data, unless we have a legal obligation to retain such data or for legitimate business purposes. You can contact us ([email protected]).

Please note that we cannot delete business data . This is because the retention and processing of data in the lending business involves complex business processes and regulatory requirements. Once the loan transaction is completed, some key data may be retained to maintain the normal operation of the system.

UPDATES TO THIS PRIVACY POLICY

twaleloan (Originally named SwiFund) may update its Privacy Policy from time to time, and at it’s sole discretion. We will notify you when changes have been made.

By continuing to use the mobile application or website after the change, you agree to the terms stated in the new policy.

CONTACT US

twaleloan (Originally named SwiFund) ensures that our day-to-day processes comply with this Privacy Policy.

To contact us, please send an email to

[email protected]