Privacy Policy

Trustrock Fintech Nigeria Limited (“we” “our” “us”) respect the privacy of our online visitors and registered users (“User” “You” “Your“). We are committed to protecting your Personally Identifiable Information (“PII”) that may be collected through your use of our website or mobile application GetNaira (“Site” “App”) or in applying for or receiving any of our products or services (“Services”).

This privacy policy ("Privacy Policy") is formulated in accordance with the National Information Technology Development Agency Act 2007, Nigeria Data Protection Regulation 2019. Your personal information that we collected including sensitive personal information is protected by laws.

This Privacy Policy together with our Terms and Conditions as set out at here and any additional applies to your use of GetNaira mobile application software available on our site or hosted on the Apple App Store, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading the App, you confirm that you have read, understood and accept the terms of this Policy set out hereunder. You also consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy.

A. Information we may collect from you

We may collect and process the following data about you.

i. Information you give us about you (Submitted information):

This may include information:

provided by filling in forms when visiting our sites or on our App;

provided by corresponding with us (for example, by e-mail or chat);

provided by downloading or signing up on the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App's social media functions, entering a competition, promotion or survey, and reporting a problem with the App, our Services, our App Site or any of Our Service Sites.

This information may include your name, date of birth, gender, physical address, phone number, e-mail address, photograph, education background, working information, marital status, religion, emergence contact and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable).

ii. Information we collect about you and your device.

Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:

technical information, including the type of mobile device you use, unique device identifiers, information about the SIM card used by the Device, mobile network information, your Device' s operating system, the type of browser you use, or your Device' s location and time zone setting (Device Information);

information gathered on your Device, including advertisement, calendar or other digital content (Content Information);

Advertisement. Granting permission for the application to access your IDFA (Identifier for Advertisers) data allows it to track and enhance your product experience during the loan application journey, ultimately elevating your overall loan experience.

Calendar. Create and edit repayment logs in the calendar to remind you to repay the loan.

data from your use of any other third-party application on the Device or the Service Site.

iii. Location Information.

We also use GPS technology or other location services to determine your current location. You can withdraw your consent to our collection, processing or use of this information at any time by logging out and uninstalling the App from your Device.

iv. Information we receive from other sources (Third Party Information).

Due to the nature of the Services which we provide, we are required to work with a number of third parties (including credit reference agencies and mobile network providers) and we may receive information about you from them.

B. Tracking and cookies

We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site, or Service Sites. This helps us to provide you with a good experience when you use the App or browse any of the Service Sites and also allows us to improve the App and Our Service Sites.

C. Uses made of the information

We may associate any category of information with any other category of information and will treat the combined information as Personal Information in accordance with this Policy for as long as it is combined.

We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by applicable law:

i. We may use your Personal Information:

to identify you and to register you as a user and to administer, manage or verify your account and your credit conditions as such;

to facilitate or enable any checks as we may in our discretion consider necessary before we register you as a user;

to disburse Loan and collect payments for your use of the Service;

to build credit models and perform credit scoring;

to comply with Applicable Law, regulations, and rules, such as those relating to “know-your-customer” and anti-money laundering requirements;

to communicate with you and to send you information in connection with the use of the App;

to notify you of any updates to the App or changes to the Service (including interest rate, Transaction Fees, etc.) available;

to process and respond to enquiries and feedback received from you;

to maintain, develop, test, enhance and personalize the App to meet your needs and preferences as a user;

to contact you by telephone using auto-dialed or pre-recorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy and the Terms of Use;

to monitor and analyze user activities and demographic data including trends and usage of the Service available on the App.

ii. We may also use your Personal Information more generally for the following purposes (although we will in each such case always act reasonably and use no more Personal Information than what is required for the particular purpose):

to undertake associated business processes and functions;

to monitor usage of the App and administer, support and improve the performance efficiency, user experience and the functions of the App;

to provide assistance in relation to and to resolve any technical difficulties or operational problems with the App;

to generate statistical information and anonymous analytics data for the purpose of testing, research, analysis and product development;

to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities;

to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us and/or any of our Affiliates; and

to enable us to comply with our obligations under any Applicable Law (including but not limited to responding to regulatory enquiries, investigations or directives) and conducting audit checks, due diligence and investigations.

Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties.

D. Disclosure of your information

We may disclose some or all of the data we collect from you when you download or use the App to credit reference bureaus.

We may disclose your personal information to any member of our group, which means our subsidiaries, affiliates, our holding company and its subsidiaries.

We may disclose your personal information to third parties:

in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

if GetNaira or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or

in order to: enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

E. Where we store your personal data

The data that we collect from you may be transferred to and stored at a destination outside your country of origin or residence (as applicable) where the data protection laws may differ from those in your jurisdiction. It may also be processed by staff operating outside your country of origin or residence (as applicable), who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests on the Service Sites. By submitting your personal data, you agree to the collection, transfer, storing or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this Policy.

F. Security of Data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Notwithstanding the undertaking above, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, using global best practices, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences.

If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. You are reminded to log off from your account and close the browser when finished while using a shared computer.

G. Your Privacy Rights

You have the following privacy rights:

i. Right to Rectification

You can modify or change your name, email, password, and mobile login PIN through your profile.

ii. Right of Access, Erasure, and Restrict Processing

You can request access or erasure of your personal information, as well as request restriction on further processing of your data/personal information by contacting us at trustrockfintech@outlook.com. Please allow up to 30 days for requests to be processed. We reserve the right to charge a reasonable fee to process excessive or repeated requests.

iii. Right to Withdraw Consent

You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send, or by adjusting your Marketing Preferences in your profile. You can also have choices with respect to cookies, as described above.

By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Service may not work properly in your case.

iv. Right to lodge a complaint with a supervisory authority

Should you feel your data privacy rights are not being adequately protected by us, you have the right to lodge a formal complaint with the appropriate supervisory authority.

H. Legal Age

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child or children have provided us with personal data, please contact us at trustrockfintech@outlook.com. If we become aware that we have collected personal data from children without verification of parental consent, we shall take steps to remove that information from our servers.

I. Links to Other Sites

The App may provide hypertext links to other sites operated by other people. Using such a link means you are leaving the App. We take no responsibility for, and gives no warranties, endorsements, guarantees or representations in respect of, linked sites. We are not responsible for the privacy practices, nor do we accept any liability in connection with the content of, such websites or applications, which will in some cases have their own privacy policies tailored for the particular business practices in which they operate. Any concerns regarding any external link should be directed to its website or app administrator.

J. Changes to the Policy

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Service Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. In any event, by continuing to use the App or any Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.

K. Contact Us