This data privacy, protection and cookie policy describes your privacy rights regarding Altracred Finance Investment Limited (“we”, “us” or “our”) collection, use, storage, sharing and protection of your personal information. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the services and tells you about your privacy rights and how the law protects you. It applies to all forms of systems, operations and processes within the Altracred Finance Investment Limited environment that involve the collection, storage, use, transmission and disposal of Personal Information.
This Data Privacy, Protection and Cookie Policy (the “Privacy Policy”) will help you understand how we use your information and what we do with it. However, this Privacy Policy does not apply to services that are not owned or controlled by Altracred Finance Investment Limited, including third-party websites and the services of other our merchants.
We respect the privacy of our online visitors and registered users (“Users”) as such we will take reasonable steps to protect your information.
Provided you click the button of “I accept ‘Users privacy protection agreement’ ” in the Registration page of Weshare platform when you log on, you will be deemed to have agreed to, acknowledged, accept the terms and conditions of this Agreement and consent to the processing of Personal Information relating to certain services, thus, the Agreement shall be binding between the User and Altracred Finance Investment Limited.
To use our APP or any of our products or services, your consent is required for the use of your data as described in this Privacy Policy.
1. Company Overview
Altracred Finance Investment Limited provides an online lending platform to Users.
This Privacy Policy is intended to set certain standards across the operations of Altracred Finance Investment Limited.
2. Updates, Modifications & Amendments
Altracred Finance Investment Limited may need to update, modify or amend its Privacy Policy as our technology evolves and as required by law. Altracred Finance Investment Limited reserve the right to make changes to this Privacy Policy from time to time and notify Users of material changes. All amended terms of the Privacy Policy shall become effective on the day that they are published on our APP.
In addition, we will notify you of any substantive or material change in this Notice by one of the following means: updating our APP, sending push notifications, e-mails or letters, by phone or by publishing announcements on our APP.
Users are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted. If a User objects to any of the changes to this Privacy Policy, the User have the right to cease using this Site, or terminate their account in the event an account has been created.
3. Age Restriction
Altracred Finance Investment Limited do not use its APP and services to knowingly solicit data from or market to children under the age of 18. If a parent guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us through the details provided in this Privacy Policy via email. Altracred Finance Investment Limited will get back to you as soon as possible and delete such information from our files within a reasonable time.
4. The Information We Collect
As part of our operations, Altracred Finance Investment Limited collects and processes the following types of information in order to provide you with a safe, personal and seamless access to our Service, including but not limited to:
a. Mobile phone(device)
Collection and monitoring of specific information about your equipment, including but not limited to your device name, model, regional and language Settings and equipment identification number, equipment, software and hardware information, status, habits, such as IMEI and serial number unique device identifier, with unique identification equipment and to ensure that unauthorized devices shall not on behalf of you to take action to prevent fraud.
b. Location
We need your device location authorization to collect location-related information, which includes the location method of the user device, location time, longitude, latitude, current location, location area code, etc.
c. Contacts
We need your address book permission to collect all your contacts including contact name, phone number, and date contact added. The purpose of using the address book information is to confirm your credit rating, to support the add contact function when applying or borrowing and effectuate your recovery undertakings.
d.Camera
Use the camera to take documents and / or photos required for the application and evaluation process. First name and last name
e. Media File
Credit assessment will be conducted on you through your uploaded identification picture, so that you can quickly obtain the credit and experience smooth lending services. Address, State, Province, ZIP/Postal code, City
f. Installed Applications
Altracred Finance Investment Limited will also read the list of apps installed on your device, including the app name, installation time, installed version, etc. This will be used to identify the presence of malware, cheats, so as to maintain the security of the mobile system environment and lending services. Bank Verification Number (BVN)
g. Phone number
Altracred Finance Investment Limited will also obtain your local number to assist in identifying your identity to ensure the security of your account and funds. Once any abnormality is found, we will freeze your account in time and send you a notice in time.
h. Calendar
Altracred Finance Investment Limited also need you to grant read and write access to the calendar, which will allow us to alert you in advance of the repayment date to avoid late fees; At the same time, we will not delete or modify the information you have written, but only evaluate the loan schedule to confirm your loan eligibility.
i. Other data that will be collected
To gain full access to our APP and services, you must register for a Weshare account. When you register for the Service, we will collect your bank number and phone number and may also collect your name, age, email address or other contact information. With these information, we cross-check your identity with third parties, including emergency contacts you have provided. To supplement this information, we will also collect data from third parties, such as credit bureaus and other financial institutions, with your consent. By authorizing the collection and processing of the above data, we will ensure that your data is protected with strict standards.
Altracred Finance Investment Limited collects certain data in order to be able to provide services to you. We also collect data used to verify your identity and create credit scoring models to determine which loans can be offered to you. We also use this data for collections and credit reports. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings.
Altracred Finance Investment Limited is firmly committed to complying with applicable data protection laws, regulations, rules and principles to ensure security of Personal Information handled by the Company,and will not trade your information with any third party transactions.
Purpose Limitation
Altracred Finance Investment Limited collects Personal Information for identified purposes, and provision of loaning service, and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose. These individuals include current, past and prospective employees, merchants, suppliers/vendors, customers of merchants, Users and other individuals whom Altracred Finance Investment Limited communicates or deals with, jointly and/or severally (“Data Subject(s)”).
Data Minimization
Altracred Finance Investment Limited limits Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.
5. Cookies
We use cookies to identify you as a User and make your user experience easier, customize our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our APP. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.
Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.
If your browser or browser add-on permits, you have the choice to disable cookies on our APP, however this may impact your experience using our APP.
6. How We Protect Your Information
Altracred Finance Investment Limited shall establish adequate controls in order to protect the integrity and confidentiality of Personal Information, both in digital and physical format and to prevent Personal Information from being accidentally or deliberately compromised.
Altracred Finance Investment Limited are committed to managing your Personal Information in line with global industry best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration, we also use industry recommended security protocols to safeguard your Personal Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to Personal Information to only employees who require it to fulfil their job responsibilities. Any Personal Information processing undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties is unauthorized.
Employees may have access to Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Information for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.
7. Processing and Transfer of Personal Information
Third Party Processor within Nigeria
Altracred Finance Investment Limited may engage the services of third parties in order to process the Personal Information of Data Subjects collected by us. The processing by such third parties shall be governed by a written contract with us to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with the terms of this Privacy Policy.
Your personal information will only be shared confidentially in the following situations:
a. share with service providers to monitor and analyze the use of our services, to contact you
b. share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business to another company.
c. share Your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with Us.
d. share Your information with our business partners to offer you certain products, services or promotions.
e. disclose your personal information for any other purpose with Your consent.
We may retrieve additional Personal Information about you from third parties and other identification/verification services such as your financial institution and payment processor.
Transfer of Personal Information to Foreign Country
Where Personal Information is to be transferred to a country outside Nigeria, we will put adequate measures in place to ensure the security of such Personal Information. In particular, we will, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) White List of Countries with adequate data protection laws.
Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation. We will therefore only transfer Personal Information out of Nigeria on one of the following conditions:
a. The consent of the Data Subject has been obtained;
b. The transfer is necessary for the performance of a contract between Altracred Finance Investment Limited and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request;
c. The transfer is necessary to conclude a contract between Altracred Finance Investment Limited and a third party in the interest of the Data Subject;
d. The transfer is necessary for reason of public interest;
e. The transfer is for the establishment, exercise or defense of legal claims;
f. The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
g. We will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.
Grounds for Processing of Personal Information
Processing of Personal Information by Altracred Finance Investment Limited shall be lawful if at least one of the following applies:
a. users have given their consent for one or more specific purposes;
b. the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
c. processing is necessary for compliance with a legal obligation to which Altracred Finance Investment Limited is subject;
d. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party; and
e. processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Altracred Finance Investment Limited.
For the purpose of this Privacy Policy, consent means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.
8. Choices and Rights
Individuals who have Personal Information held by us are entitled to reach out to us to exercise the following rights to:
a. Request for and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format;
b. Information on their personal information collected and stored;
c. Request objection or request for restriction;
d. Object to automated decision making;
e. Request rectification and modification of Personal Information which we keep;
f. Request for deletion of their data;
g. Request the movement of data from us to a third party; this is the right to the portability of data; and
h. Object to, and to request that we restrict the processing of their information
Users’ request will be reviewed by our Data Protection Officer (DPO) and carried out except as restricted by law or our statutory obligations. You may decline to provide your personal Information when it is requested by us, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.
9. Retention of your information
For all collected information, we will store it on our server in a highly protected manner, and will not sell, trade or rent this information to any third party. However, in order to provide you with services, we may share your information with trusted third parties for services such as payment and identity verification in borrowing.
Altracred Finance Investment Limited will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations or verify your information with a financial institution.
Altracred Finance Investment Limited is statutorily obligated to retain the data you provide to us, in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us, our banking providers and card processors.
Therefore, even after closing your Altracred Finance Investment Limited account, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by us where possible. For all Personal Data and records obtained, used and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.
The length of storage of Personal Information shall, amongst other things, be determined by:
a. the contract terms agreed between Altracred Finance Investment Limited and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
b. whether the transaction or relationship has statutory implication or a required retention period; or
c. whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require Altracred Finance Investment Limited to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
d. whether we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
10. Data Protection Officer (DPO)
If you have any questions relating to this Privacy Policy or would like to find out more about exercising your data protection rights, please reach out to our DPO via email at service@weshareloan.ng.
Altracred Finance Investment Limited maintains a data breach procedure in order to deal with incidents concerning Personal Information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored or otherwise processed.
Users are required to contact our DPO upon becoming aware of any breach of Personal Information or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your Personal Information or account.
