Privacy Policy

(Effective Date: November 11, 2024)

 

1. SCOPE OF THIS PRIVACY POLICY

 

1.1 Nature Lending Nigeria Limited ("Futurecash"), a Federal Competition & Consumer Protection Commission approved Digital Money Lender of Nigeria and the data controller responsible for processing your data when you download and use the Futurecash mobile application ("Futurecash App") hosted on the Google Play Store or when you access our Services through other Channels.

 

1.2 Futurecash may also act as a data processor for a data controller with whom you have a contractual relationship. In such instances, Futurecash will act in accordance with the instructions given by the data controller.

 

1.3 If you have any questions about this Privacy Policy, please contact us via email at help@naturelendingltd.com.

 

1.4 Please read this Privacy Policy carefully to understand our practices regarding your Personal Data in accordance with the National Information Technology Development Agency Act 2007, Nigeria Data Protection Act 2023. By expressing your acceptance of the terms of this Privacy Policy (through the Futurecash App, or other Channels ), you accept and understand that your Personal Data will be processed in accordance with this Privacy Policy.

 

1.5 Futurecash's Services are not intended for children, and we do not knowingly collect data relating to children.

 

2. DEFINITIONS

 

2.1 "Privacy Policy" means the Futurecash Privacy Policy (available within the Futurecash App and on the Futurecash website) that sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be stored and processed by us.

 

2.2 "Channels" means any system or medium (including the Futurecash App, and web whether internet based, mobile device based or not), which may be established by Futurecash from time to time to enable you to access and utilise one or more of the Services.

 

2.3 "Children" means individuals below the age of eighteen (18) years.

 

2.4 "Consent" means an express, unequivocal, free, specific, and informed indication of your wishes by a statement or by a clear affirmative action.

 

2.5 "Customer" or "User" means any individual within the Federal Republic of Nigeria to which Futurecash provides its Services.

 

2.6 "Personal data" means personal identifiable information includes but is not limited to name, address, phone number, identification number, location data, date of birth, gender, transaction data, an online identifier or information relating to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of such person. It also includes any information relating to an identified or identifiable individual, which shall include Sensitive Personal Data.

 

2.7 "Sensitive Personal Data" means Personal Data about an individual's race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of the individual's child(ren), parent(s), spouse(s), or the individual's sex or the sexual orientation. It also includes sensitive information specified by Google Play Policy, including dangerous and special permission to obtain device data. Sensitive Personal Data also hereinafter referred to as "Personal Data"

 

2.8 "Services" refers to the financial products and features provided by Futurecash to Customers through the Futurecash App, through its partner channels, or through other Channels.

 

2.9 "We", "Our" and "Us" refer to Nature Lending Nigeria Limited and Futurecash.

 

2.10 "You" or "your" means the Customer and includes the personal representatives of the Customer.

 

3. CONSENT AND AUTHORIZATION

 

3.1 By downloading the Futurecash App and clicking "Accept" on the permissions overview screen, you: 

 

• Accept the terms of this Privacy Policy;
• Allow Futurecash to access the device permissions more fully described below;
• Give Futurecash consent to collect, use, share, or otherwise process your Personal Data, which may include personally identifiable information, personal information or sensitive personal information (in each case, as defined under applicable law), as outlined in this Privacy Policy;
• Certify that all Personal Data you have provided and will provide to Futurecash is true and correct to the best of your knowledge; 
• Authorize Futurecash to verify/investigate the accuracy of your Personal Data; and
• Acknowledge that Futurecash may be required to disclose your Personal Data to the Central Bank of Nigeria, Federal Inland Revenue Service, Credit Information Corporation, credit bureaus and/or any other governmental body, in compliance with its legal obligations and in accordance with the principle of proportionality.

 

4. THE PERSONAL DATA WE COLLECT ABOUT YOU

 

4.1 Futurecash will collect Personal Data from you as you use our Services. This includes the following:

 

• Emergency Contact Data: includes relationship with the emergency contact, name, and mobile numbers. We do not access or collect all contact information in your phone book.
• Profile Data: includes your level of education, employment status and income information, marital status, and other details you submit in response to surveys administered by Futurecash or Futurecash's agents.
• Contact Data: includes your present address, permanent address, email address, and mobile numbers.
• Financial Data: includes your bank account number, remittance account number, and payment card details.
• Device Data: includes the type of mobile device you use, device specifications (such as screen size, resolution, memory, or CPU capacity), unique device identifiers (IMEI number, IP address, Android ID, Google Play services ADID, MAC address), mobile network carrier, and mobile operating system.
• Device behavioural data: includes information stored on your device, such as SMS data, calendar data, device usage data, and inventory of installed apps.
• Usage Data: includes your username, password or PIN, OTP, and details of your use of the Futurecash App or Channels.
• Marketing Data: includes your preferences in receiving promotional messages from us and our authorised third parties, as well as data provided by you in relation to special offers and promotional activities conducted by Futurecash.
• Device Location Data: includes your current location determined by geolocation technology.
• Third Party Data: includes information about you that we obtain from partners, credit reference agencies or bureaus, external collection agencies, identity verification and sanctions screening Service providers, mobile network providers, and marketing partners.

 

4.2 The details of Device Data, Device Location Data, and Device behavioural data (Sensitive Personal Data) from you as you use our Services:  

 

• Phone State data. We collect phone state data to prevent fraudulent user activities and ensure that unauthorized devices are not acting on your behalf. This include details such as device model, operating system version, unique device identifier(e.g., IMEI), IP address, and network information.

• Device Location data. We need to access your current location information during the loan application process to enable fraudulent user identification and ensure that you are using our service in Nigeria. This include detail such as latitude and longitude based on network IP address.

• SMS data.  We need to access your SMS information to enable user credit risk assessment and recommend personalized credit loans. This include details such as the sender and recipient's names, the messages' content, and their timestamps. We employ a targeted filtering system to ensure that only relevant financial messages are analyzed, keeping all other messages private. This data allows us to assess your credit risk more accurately and speed up the loan approval process.

• Inventory of installed apps data.  We collect the inventory of installed apps data to enable user credit risk assessment, understand user behavior, and recommend personalized credit loans. This include details such as the app name, app version, and the installed time on your device.

• Calendar data. We need to access your calendar information to enrich the user's credit risk profile. In addition, we can add the repayment event of your loan to remind you. This include details such as the event title, event description, and start/end date. We employ a targeted filtering system to keep all information private.

• Package usage data.  We need to access package usage data to understand user behavior and enrich credit risk profile and improve the success rate of loan approvals. This include details such as the app package id, the time and frequency of your app usage, activity status of the apps.

 

4.3 We also may collect other information about you, your device, and your use of the app or Channels in ways that we describe to you at the time of collection. 

 

 

4.4 We process your Personal Data from the following sources:

 

4.4.1 Information you give us. This is information you submit to us or allow us to access by expressing your acceptance in the Futurecash App, or by other recorded means, including by filling in forms or by corresponding with us or interacting with our website or social media accounts.

 

4.4.2 Information we collect from your device. This is information you allow us to access by installing the Futurecash App or accessing our Channels on your Device and enabling certain device permissions.

 

4.4.3 Third Party Data and publicly available sources. We may receive Personal Data about you from various third parties, partners and public sources such as:

 

• Financial, Profile and Transaction Data from providers of technical, payment, delivery, and general financial Services such as mobile network providers, money Service businesses, and external collection agencies.
• Contact, Financial, Profile and Transaction Data from identity verification and sanctions screening service providers and credit reference agencies.
• Communications Data from your interactions with our external collection agencies.
• Identity, Profile, and Contact Data from partners and publicly available sources.

 

4.5 Collection and processing of your Personal Data by Futurecash is necessary for the provision of Services and to comply with applicable legal and regulatory requirements to which you and/or Futurecash is subject. Apart from such cases, we do not collect and share Personal Data without your specific prior consent.

 

4.6 If you fail to provide or withhold any or all of the Personal Data that Futurecash requests, we may be unable to provide you with our Services.

 

4.7 With your consent and authorization, we access Personal Data, which will be encrypted and uploaded via https://api.naturelendingltd.com to the Futurecash server while the App is in use. We will not collect and upload data when the app is in the background or inactive.

 

4.8 We never publicly disclose, sell, or use your Personal Data for any other purposes.

 

5. PURPOSES AND LAWFUL BASIS FOR WHICH WE WILL USE YOUR PERSONAL DATA

 

5.1 We will only process your Personal Data when we have a lawful basis to do so. In most instances, we will process your Personal Data under one of the following circumstances:

 

• Where you have given your consent for the processing of your Personal Data.
• Where we need to perform a contract with you, or where we need to take steps at your request before entering into a contract with you.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party), and where your interests and fundamental rights do not override those interests.

 

5.2 If you fail to provide or withhold any or all of the Personal Data that Futurecash requests, we may be unable to provide you with our Services.

 

 

6. USAGE OF YOUR PERSONAL DATA

 

6.1 We may make certain decisions in relation to our provision of our products and Services to you by using automated decisions and profiling function, without human involvement.

 

6.1.1 When you apply for credit, we'll use automated processing to decide whether to lend to you and/or make other decisions about your eligibility for our products and Services, based on the Personal Data collected. This automated processing enables us to provide rapid, responsive  and tailored credit Services to customers who may not have credit histories, prior bank or other financial data or income from formal sources. 

 

6.1.2 Our credit and underwriting models utilize data science and machine-learning technology to process your Personal Data and assess your creditworthiness. The associated processing of your Personal Data is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for our Services or ineligible for credit of a particular amount or tenure. Our  credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.

 

6.1.3 Futurecash also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual's access may be suspended or refused. 

 

6.2 Your rights in relation to automated decision-making.

 

6.2.1 If you apply for a credit and your request is declined (or you are informed that you are ineligible for other or associated products or Services) as a result of an automated credit, underwriting or fraud decision, you may request that one of our underwriters review this decision. You may do so by contacting us at: help@naturelendingltd.com. You may also object to the automated processing of your Personal Data, but doing so will prevent us from providing you with our Services. 

 

7. DISCLOSURES OF YOUR PERSONAL DATA

 

7.1 When you consent to providing us with your Personal Data, we will also ask you for your consent to share your Personal Data with the third parties set out below for the purposes set out in the table above.

 

7.2 External Third Parties such as:

 

7.2.1 Data controllers with whom you have a contractual relationship and for whom Futurecash acts as a data processor;

 

7.2.2 Mobile money providers whom we use for verification in relation to your mobile money account, pursuant to the agreement between you and the relevant mobile money provider;

 

7.2.3 Credit bureaus and/or any other reliable sources from whom we may obtain your Personal Data and also supply your consumer credit information which may include information on repayments and defaults and account opening and closing;

 

7.2.4 Any local or international law enforcement or competent regulatory or governmental agencies in connection with an official request so as to assist in the prevention, detection, investigation or prosecution of criminal activities or fraud;

 

7.2.5 Futurecash's Service providers, such as external collection agencies, who are acting as data processors upon the instructions of Futurecash;

 

7.2.6 Futurecash's agents or any other company that may be or become Futurecash's affiliate entity, for reasonable commercial purposes relating to the Services;

 

7.2.7 Futurecash's professional advisors and consultants including lawyers and auditors or to any court or arbitration tribunal in connection with any legal or audit proceedings;

 

7.3 Third parties to whom we may choose to sell, assign, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

 

7.4 Any other person that we deem legitimately necessary to share the data with, in all cases in compliance with the Nigeria Data Protection Act 2023.

 

8. INTERNATIONAL TRANSFERS

 

8.1 Your Personal Data collected by Futurecash shall be stored and processed outside of Nigeria in a location where Futurecash or its agents maintain facilities, including the use of cloud storage and cloud computing technology.

 

8.2 Whenever we transfer your Personal Data outside of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring adequate safeguards are implemented. We ensure your Personal Data is protected by requiring all our group companies, personnel, and agents to follow the same rules when processing your Personal Data.

 

9. DATA GOVERNANCE AND SECURITY

 

9.1 Futurecash implements an Information Security Management System to maintain the confidentiality, integrity, and availability of Futurecash's information resources, in keeping with our commitments, industry standards and global best practices. You may refer to our Privacy Policy for further details on the data governance and security measures that we implement.

 

9.2 Where you have chosen or have been given a password, PIN or OTP code that enables you to access certain parts of the Futurecash App or Channels portal, you are responsible for keeping this password, PIN or OTP code confidential. Never share this password, PIN or OTP code with anyone. Futurecash will never ask you to provide us with your password PIN or OTP code.

 

9.3 We have put in place procedures to deal with any suspected breach of Personal Data and will notify you and any applicable regulatory authority when we are legally required to do so.

 

10. DATA RETENTION

 

10.1 Your Personal Data will be stored or retained by Futurecash and its transferees only for so long as necessary for the purposes listed in this Privacy Policy, and for a reasonable time thereafter for the delivery of our products and completion of our Services.  We are required to retain your Personal Data for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, notwithstanding requests for deletion. We may also retain your Personal Data (i) for as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defenses. Information that is no longer needed for the purpose(s) for which it was collected shall be deleted or anonymized except as necessary to comply with legal obligations.

 

10.2 In some circumstances, such as when you have no outstanding loan orders with Futurecash, you can ask us to close your Futurecash account and delete the associated Personal Data: see the section on Your Data Subject Rights below for further information.

 

10.3 In some circumstances we will anonymise your information such that it will no longer constitute Personal Data. In such cases we may use anonymised information for whatever legitimate purpose without further notice to you.

 

11. YOUR DATA SUBJECT RIGHTS

 

11.1 As a data subject, you have the following rights in relation to your Personal Data:

 

11.1.1 To be informed of the uses for which your Personal Data is processed;

 

11.1.2 To access your Personal Data in our custody, as well as information about:

 

• The purposes for which we process your Personal Data;
• The categories of Personal Data processed;
• The recipients or categories of recipients to whom the Personal Data have been or will be disclosed;
• Where possible, the period for which the Personal Data may be stored, or the criteria used to determine the period for storage and retention;
• Where the Personal Data is not collected from you as the data subject, any available information as to the source of collection.

 

11.1.3 To object to the processing of all or part of your Personal Data (unless we have compelling legitimate interests to continue the processing, or when it is necessary for the establishment, exercise, or defence fo a legal claim);

 

11.1.4 To correct or rectify false, inaccurate, outdated, incomplete, or misleading data about you (subject to verification, such as examination of supporting documents);

 

11.1.5 To erase or delete data that is false, misleading, irrelevant, excessive, unlawfully obtained, or which we are no longer authorised to retain. Your right to erasure will not apply if it is necessary for us to continue to process your Personal Data to comply with a legal obligation, or for to establish, exercise, or defend a legal claim.

 

11.1.6 To copy, port, or receive your Personal Data in a structured, commonly used, and machine-readable format, or to have your Personal Data ported to another data controller or data processor.

 

11.2 You may request that we restrict the processing of your Personal Data in the following circumstances:

 

11.2.1 Where need to verify the accuracy of data that you are contesting;

 

11.2.2 Where our use of the data is unlawful but you do not want us to erase it;

 

11.2.3 Where the purpose of the processing has been achieved, but the we need your Personal Data to establish, exercise or defend legal claims;

 

11.2.4 You have objected to our use of your data but we need to determine whether we have overriding legitimate grounds to use it.

 

11.3 You have the right to object to the processing of your Personal Data for direct marketing purposes, and you can opt out of direct marketing communications by asking us not to send you direct marketing messages.

 

11.4 You may withhold or withdraw your consent in cases where we rely on your consent as the lawful basis for processing of your Personal Data. Doing so may prevent us from providing you with our Services.

 

11.5 You or your authorised representative can exercise any of these rights at any time, subject to our verification and review, by contacting us via email at help@naturelendingltd.com.

 

11.6 You may request the closure and deletion of your Futurecash App account by in-app application or submitting an form through the external application link. Futurecash reserves the right to deny the request when the request cannot be verified, when your account has an outstanding loan orders or is under investigation, or when we have any other legal basis to retain your Futurecash App account and the associated customer data. Under anti-money laundering regulations, Futurecash is required to retain customer information for at least five (5) years. Notwithstanding requests for deletion of a Futurecash App account, Futurecash will retain records of customer information (such as: customer due diligence and identification records and transaction records) until the regulatory retention period has expired.

 

12. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

 

12.1 We keep this Privacy Policy under regular review. Changes to this Privacy Policy will be posted on this page and, where appropriate, notified to you through either the Futurecash App or Channels, Website email, or SMS.

 

12.2 It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during our relationship with you.

 

13. THIRD PARTY LINKS

 

13.1 Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any Services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or Services. Please check these policies before you submit any Personal Data to these websites or use these Services.

 

14. GENERAL

 

14.1 If you have questions about this Privacy Policy or about your rights as a Data Subject, you can contact us at: help@naturelendingltd.com.