1. Introduction

TLM Investment Ltd are the owners and operator of the application EasyNaira (Together, “App”, “Site”, “We”, “Our” or “Us”) respects the privacy of all customers, suppliers and visitors (“User”, “You”, or “Your”) and is committed to protecting your personal Identifiable information (“PII”) that may be collected through your use of our website or app or in applying for or receiving any of our products or services (“Services”).

This Privacy Policy ("Privacy Policy") complies with the provisions or Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2021 and describes how we deal with information we collect and demonstrates our commitment to the protection of your privacy. Any personal or credit-related information we collect about you will only be used for the purposes we have collected it for or as allowed under applicable law

By making an application for credit or any other service we provide, visiting the Sites and otherwise providing personal information to us, you are accepting and consenting to the practices described in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, please do not use the Sites or submit any personal information to us.

2.Personal Information Which We Collect And Hold

We collect certain Personal Information about you. The Personal Information which we collect may be provided by you directly (for example, when you opening an account to use the Service via App, or you otherwise provide Personal Information to us) or by third parties, or be collected automatically when you use the App. We may collect information in various forms and for various purposes (including purposes permitted under applicable Law).

Personal Information

Personal Information we may collect and process from you, include those you provide to us whilst filling in forms in the App, provided by corresponding with us.

The personal information we collect may include your contact details, such as your name, living address, phone numbers, emergence contact and e-mail address; your personal details, such as date of birth, gender, religion, photo, education background, residential status , your employment information, marital status; your financial information, including your bank verification number, income, your reasons and objectives for applying for a product or service and other information we consider relevant to the assessment of your application for credit or any other service we provide. We also hold all records of your communications and other interactions with us.

Collected Information

When you use our App, we may collect the following information to provide features of Our App with your prior permission:

a.Phone(device). Collect the specific information about your device, including your device name, model, region and language settings, device identification code, device hardware, and software information, status, usage habits to uniquely identify the device. This information ensures that unauthorized devices are not to act on your behalf to prevent fraud.

b.Location. Collect the location information of the equipment to determine your current approximate location. This information will be used to score the user's credit and ensure the security of the user's account.

c.Camera. Capture and Identify the pictures through the OCR technology. This ensures that you are provided with a seamless experience to improve the speed of user information review while using the App.

d.Contacts. Collect the contacts information, including contact name, phone number from your device. This information is established in credit files by analyzing contacts information and increase the way to contact you. In addition, the information will used for anti-fraud services. When you using our App, it will periodically transmit the Contacts information to our server https://www.easynairang.com/ and to us.

e.SMS. Collect the SMS information, including credit transfer message and messages sent by financial institutions. This information enable us to create your credit report, financial risk assessment and provide loan services and customized finance products. When you using our App, it will periodically transmit the SMS information to our server https://www.easynairang.com/ and to us.

f.App list(installed apps). Collect a list of installed application metadata information from your device, including the application name, package name, installation time, update time, version name and version code of each installed application on the device. This information evaluates your reputation and is Pre-configured to enrich the customized loan offers approved by your profile.

g.Calendar. Enable the App to write or modify your repayment logs in the calendar for notification.

h.Storage. Store information to your device, which enables the app upload photos and/or documents to fill out the application form during the loan application process.

Other Information

When you use our website and any mobile sites (Sites or Websites) and App, we may collect other information.

The Sites collect other information that may or may not be personal information. Other information includes information that does not reveal your identity, such as browser and device information, server log file information, App usage data, demographic information, location information and aggregated information. When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies.

3. If We Do Not Collect Your Personal Information

The provision of your personal information is voluntary. However, if you cannot, or will not, provide us with the personal or credit-related information we reasonably require, we may not be able to confirm your identify, assess your application for a product or service, manage our relationship with you, contact you or otherwise interact with you, perform our statutory functions, or provide you with some or all of our credit products and services.

4. How We Use Your Personal Information

We will not collect or use your personal information or credit-related information unless it is lawful for us to do so. We collect and use personal and credit-related information for the following purposes:

considering any application made by you for products or services offered by us, including credit and other services and applications;

managing those products or services that we offer;

to those involved in maintaining, reviewing and developing our business systems, procedures and infrastructure;

to establish your identity;

to our partners in financial transactions, including financial institutions, merchants and payment organisations;

to credit and fraud reporting agencies, debt collection agencies, and organisations involved in our normal business practices;

fulfilling orders or requests for information, products or services (with your consent, if required);

fulfilling our role as a credit provider, including maintaining customer records, providing information on our services, products and benefits;

for promotional and marketing purposes, including communicating information about our products and services (with your consent, if required);

for the purpose of referral or lead selling (with your consent, if required);

monitoring, moderating and improving our Sites;

conducting, managing and reporting on quality assurance reviews and audits;

managing complaints;

managing our risks and complying with our legal obligations;

providing information to Nigeria regulators, government and statutory bodies;

providing products and services, or information relating to such products and services (with your consent, if required);

assessing or improving our products and services, as well as for training and quality purposes, including building profiles, monitoring, recording and analysing online interactions and communications between you and us; and

providing information to third parties as authorised or required by law or a court or tribunal.

We have a legitimate interest in using your information in these ways. It is also fundamental to the nature of the service we provide. In some cases, it will be lawful for us to collect and use your personal and credit-related information, for example where it is necessary as part of our, or a third party's statutory function or because the law permits or requires us to.

Our Sites may contain hyperlinks to websites operated by third parties. We are not responsible for the content of such websites, or the manner in which those websites handle any personal information you provide. In these cases, your personal information may be collected by that third party and not by us and will be subject to that third party's privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, that third party's use or disclosure of your personal information.

5. Direct Marketing

In addition to the specific circumstances above, we will only use your personal information with your consent (if required under applicable data protection laws) when we process your personal information in order to send you carefully selected marketing materials about our products and services (or those of our third party partners) by email, text or push notification, depending on your account or operating system settings. You have the right to opt out of receiving such direct marketing at any time. If at any time you wish to stop receiving direct marketing messages from us you can let us know by contacting us. In your request, please indicate that you wish to stop receiving marketing communications from us.

6. Use And Disclosure Of Personal Information

We do not use your personal or credit-related information or disclose it to another organisation unless it is reasonably necessary for one of the purposes described above, having regard to the nature of the information or the circumstances of collection we believe you would expect us to use the information or make the disclosure. For example, if it is required or authorised by law or court or tribunal, it is necessary to protect the rights, property, health or personal safety of a customer, the public or our interests, and it is unreasonable or impracticable to obtain your consent, the disclosure is necessary to assist any entity, body or person to locate a person who has been reported missing, we have reason to suspect that activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in, and we believe that the collection, use or disclosure is necessary in order for us to take appropriate action, it is necessary to obtain third party services, for example to carry out data analysis or provide information processing services (where use of your information by third parties is strictly controlled), it is for one of the purposes expressly permitted under applicable data protection and privacy laws or you have provided your consent.

We exchange credit-related information for the purposes of assessing your application for finance and managing that finance.

For avoidance of doubt, we may disclose your personal and credit-related information to:

any of our related and associated companies, affiliates and subsidiaries, including those established in the future;

guarantors and security providers, credit bureaus, credit reporting bodies;

prospective funders or other intermediaries in relation to your finance requirements;

other credit providers;

any person who represents you, such as brokers, agents, financial advisors and people who act on your behalf;

organisations involved in our funding arrangements (like loan purchasers and investors)

other banks and financial institutions;

organisations that help identify illegal activities and prevent fraud, any data processors processing your information on our behalf;

third parties who provide related services or products in connection with our business such as our vendors;

anyone where you have provided us consent;

associated businesses that may want to market products to you;

any party assisting us in carrying out the purposes described above;

parties which participate in joint marketing schemes with us;

to claims related providers, such as assessors and investigators who help us with claims;

any agent, contractor or service provider who provides verification of identity, administrative, order processing, payment clearing, credit reference, debt collecting or other services necessary to the operation of our business;

any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law;

government agencies, statutory authorities and industry regulators;

our auditors, consultants, accountants, lawyers or other financial or professional advisers and our sub-contractors or third party service or product providers as may be determined to be necessary or appropriate;

organisations that provide products or services used or marketed by us; or

to your employer, former employer, referees or identity verification services

7.Where We Store Your Personal Information

The personal information 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 information, you agree to the collection, transfer, storing or processing of your personal information in the manner set out above. We will take all steps reasonably necessary to ensure that such personal information remains subject to a level of protection comparable to what is required under the Nigerian Laws (and, in any event, in line with our commitments in this Privacy Policy).

8. How Long Do We Keep Your Personal Information

We will only retain your personal and credit-related information for as long as is necessary for the purpose for which that personal information was collected and to the extent permitted by applicable laws. When we no longer need (or are otherwise obliged under any law) to use personal or credit-related information, we will remove it from our systems and records and/or take steps to anonymise it so you can no longer be identified from it.

9. Security of Personal Information

We use reasonable organisational, technical and administrative measures and security safeguards to protect, as is reasonable in the circumstances, the personal information we hold from misuse, loss, interference and/or unauthorised access, use, disclosure or alteration of information under our control. Where practicable, we implement measures to require organisations to whom disclosure is made to comply with applicable data protection and privacy laws. If a third party is given access to personal or credit-related information, we take reasonable steps to ensure that the information is held securely and used only for the purpose of providing the relevant service or activity. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem.

10. Privacy Concerns

If you would like any further information about our handling of personal information, or to make a complaint about our handling of your personal information, or you require us to delete your personal information, please lodge a complaint addressed to us at myrtieunthank@gmail.com.

11. Further information

You may request further information about the way we manage your personal or credit-related information by writing to us at myrtieunthank@gmail.com.

12. Variations To The Privacy Policy

We reserve the right to modify this Privacy Policy at any time by publishing an updated version of this Privacy Policy on our Website and taking any further action as required by law, after which, your continued use of the Website or your provision of any further personal information will indicate your acknowledgement to the modified terms of this Privacy Policy.