Privacy Policy

Who are we?

LoanBook Limited (“LoanBook”, “our”, “we” or “us”) is a licensed money lending company in Nigeria with registered office at 188 Herbert Macauley Way, Yaba, Lagos State providing credit facilities to gainfully employed Nigerians as well establish a mechanism where previously disadvantaged people can create a credit history for use within the commercial banking sector. For questions specifically about this Privacy Notice, or our use of your personal information, please contact our Data Protection Officer by email at legal@loanbookng.com. The data controller of your personal information is LoanBook. Please note that if you contact us to make inquiry regarding this Privacy Notice or your personal information which we process or to assist you with anything relating to your personal information, we will need to authenticate your identity before fulfilling your request. We will always process any Personal Data about you in compliance with applicable data protection laws including the Nigerian Data Protection Regulation 2019 or any other data protection law that may have the force of law in Nigeria from time to time, and only for the purposes set out in this Privacy Notice.

Application of this Privacy Notice

This Privacy Notice applies to you as a borrower or a prospective borrower or customer of LoanBook, or any person who registers on any of our platforms; or accesses any of our platforms. This Privacy Notice does not apply other parties’ sites which link to or advertise on our platforms.

What do we mean by personal information?

Personal information refers to information about an identifiable human being such as your name, gender, age, date of birth, contact address, email, phone number, identification card number, your picture, your bank details. Other information that qualifies as personal information include:

• Device information: Internet Protocol address, unique device identifier, the nature and type of device which you use to access our site or services, the geographical location of your device.
• Log information: Information relating to how, when and for how long you access and use our site; pages you accessed and viewed and the time spent and what you did on the pages you accessed; your interests in terms of our services and products.
• Location information: We may use various technologies to ascertain your actual location, such as geographical data from your device.

The Personal Information We Collect

We receive and store information about you such as:

1. Information you provide to us: We collect information you provide to us when you use our service which includes:
   • your name, email address, contact address, bank account(s) and other banking details such as your Bank Verification Number, valid means of identification, telephone number, your date of birth, username/email and password, and other identifiers you might use, gender, picture, the amount of your monthly salary, your salary account, the name and contact of your employer, your contract of employment, the name and contact details of your guarantor, and other information which we may request from you from time to time. We collect this information in a number of ways, including when you apply to borrow money from Loanbook or to use any of our services; you complete a form on our website; correspond with us by phone, email, or in writing; , sign up to receive our communications; open an account with us; enter into a contract with us; carry out any other activity or transaction or use our website (About Us) or participate in surveys or marketing promotions;
   • if you give us Personal Data on behalf of someone else, you confirm that you have given them the information set out in this Privacy Notice and ensure that they understand how their Personal Data will be processed, and that they have given their permission for you to disclose it to us and for you to allow us, and our third-party service providers, to process it. We will require that anytime your provide us with personal information of someone else, that you obtain a written permission of such person authorizing you to disclose the information to us. such written permission must also authorize us to use the personal information in line with this Privacy Notice.
   • information when you choose to provide ratings, taste preferences, account settings or otherwise provide information to us through our service or elsewhere.
2. Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your network, network devices, and your computer or devices you may use to access our service. We collect this information using various technological means. This information includes:
   • your activity on our site;
   • your interactions with our emails and texts, and with our messages through any messaging channels;
   • details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
   • device IDs or other unique identifiers, including for your network devices;
   • advertising identifiers such as those on mobile devices, tablets, and streaming media devices that include such identifiers;
   • device and software characteristics (such as type and configuration), connection information including type (wifi, cellular), statistics on page views, IP address (which may tell us your general location), browser and standard web server log information;
3. Information from partners: We collect information from other companies with whom you have a relationship (“Partners”). These Partners may include (depending on what services you use): your employer, our business partners and affiliates, our payment service providers and our bank(s), credit reference agencies, and fraud prevention agencies.
4. Information from other sources: We also obtain information from other sources. We protect this information according to the practices described in this Privacy Notice, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include:
   • service providers that help us determine your location based on your IP address in order to customize our service and for other uses consistent with this Privacy Notice;
   • security service providers who provide us with information to secure our systems, prevent fraud and help us protect the security of our sites and your account with us;
   • payment service providers who provide us with payment or balance information, or updates to that information, based on their relationship with you;

Disclosure of Information

We will not disclose, for commercial gain or otherwise, your personal information other than as set out in this Privacy Notice or with your consent. We may disclose or share your personal information to or with any of the following for certain purposes:

• Our Affiliates: We may share your personal information with any affiliate of LoanBook if it is deemed necessary for the performance of a contract you have entered into with us and for other purposes described in the Why and How We Use Your Personal Information section of this Privacy Notice.
• Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage Service Providers to provide customer relationship management services, security, infrastructure and IT services, our payment processors and suppliers and any third parties who process transactions submitted by us, collection agencies to collect debts, legal and other professional advisers, consultants, and professional experts, analytics and search engine providers that assist us in the improvement and optimization of our website and services. We do not authorize them to use or disclose your personal information except in connection with providing their services
• Partners: As described above, you may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing our service to you and providing information about the availability of our service. For example, depending on what Partner services you use, we may share information:
  1. in order to facilitate re-payment of debt
  2. with Partners who will help when fraud occurs
• Protection of LoanBook and others: LoanBook and its Service Providers may disclose and otherwise use your personal information where we or they reasonably believe such disclosure is needed to
  1. satisfy any applicable law, regulation, legal process, or governmental request,
  2. enforce applicable terms of use, including investigation of potential violations thereof,
  3. detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or
  4. protect against harm to the rights, property or safety of LoanBook, its users or the public, as required or permitted by law.
• Business transfers: In connection with any reorganization, restructuring, merger, acquisition, take over or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Notice.
  
  

  Whenever in the course of sharing information we transfer your personal information to other countries, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection having the force of law in Nigeria.

Retention of Your Personal Information

We retain all personal information which we collect from you unless there is a valid technical, legal or business reason for us to delete, destroy or de-identify it (“retained information”). We will keep all retained information as long as your account with us remains active or as long as you access our site.

When you permanently deactivate/delete your account, we will only retain your personal information for as long as necessary to fulfil the purposes such as satisfaction of any legal, regulatory, accounting, reporting requirements, for the establishment or defense of legal claims (“retention period”). After the retention period, we will delete/destroy your personal information in accordance with the applicable laws. To determine the appropriate retention period for your personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and the applicable legal requirements. If you would like to know more about the retention periods we apply to your personal data, please contact Data Protection Officer.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. It is Loanbook’s policy to respect your rights and LoanBook will act promptly and in accordance with any applicable law, rule or regulation relating to the processing of your personal information.

Details of your rights are set out below:

• right to be informed about how your personal information is processed – you have a right to be informed about how we will use and share your personal information. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language. Please refer to the Why and How We Use Your Personal Information section of this Privacy Notice to see how we will use your personal information;
• right to access personal information – you have a right to obtain confirmation of whether we are processing your personal information, access to your personal information and information regarding how your personal information is being used by us, right to request a copy of the Personal Data that we hold about you. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of the request. Please note that there are exceptions to this right such as where making the data available to you would reveal Personal Data about another person or if we are legally prevented from disclosing such data or if there is no basis for your request, or if your request is excessive.
• right to have inaccurate personal information rectified – you have a right to have any inaccurate or incomplete personal information rectified. If we have disclosed the relevant personal information to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible;
• right to have personal information erased in certain circumstances – you have a right to request that certain personal information held by us is erased. This is not a blanket right to require all personal data to be deleted. We will consider each request carefully in accordance with the requirements of the applicable data protection law;
• right to restrict processing of personal information in certain circumstances – you have a right to block the processing of your personal information in certain circumstances. This right arises if you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead or if the personal data is no longer required by us, but you require the personal data to be retained to establish, exercise or defend a legal claim;
• right to data portability – in certain circumstances you can request to receive a copy of your personal information in a commonly used electronic format as well as the right to request that the personal information be transferred to another person. This right only applies to personal information that you have provided to us (for example information provided to us when signing up or subscribing to our service). Information about you which has been gathered by monitoring your behavior will also be subject to the right to data portability;
• right to object to processing of personal information in certain circumstances, including where personal information is used for marketing purposes – you have a right to object to processing being carried out by us if
  1. we are processing personal data for the performance of a task in the public interest,
  2. if we are using personal data for direct marketing purposes,
  3. or if information is being processed for scientific or historical research or statistical purposes

You may exercise any of your rights by contacting our Data Protection Officer. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may refuse to comply with your request in appropriate circumstances prescribed by the applicable data protection law.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Security

All personal information you provide to us is stored on our secure servers or those of our trusted Partners. We implement appropriate technical, organizational, administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Once we have received your personal information, we will use the procedures and security features described above to prevent unauthorized access of your personal information.

From time to time, we review our information collection, storage, and processing practices including the technical, organizational, administrative, logical, and physical security measures to keep up to date with industry best practice.

Direct Marketing

We will not send you marketing materials if you have requested not to receive them. When you register on our site, open/create account with us, apply for a loan, or to use our services, you may choose whether to receive marketing materials from us. You may refuse to accept or require us to discontinue sending marketing materials to you. If you request that we stop processing your personal information for marketing purposes, we shall stop processing your personal data for those purposes. You may opt out of receiving marketing materials from us:

1. at the time of registering on our site by not ticking the relevant “opt in” box; and
2. at any time by requesting us to desist from sending any direct marketing materials to you.

We would encourage you to make such requests via the forms and links provided for that purpose in the marketing materials we send you or by contacting our Data Protection Officer.

Protecting your personal data

We take all reasonable steps to ensure that both we and our third-party service providers protect your Personal Data. We use advanced technology, secure third-party suppliers and well-defined employee practices to help ensure that your Personal Data is processed promptly, accurately, completely and securely. We also ensure our staff are aware of their information security obligations, providing training, and limiting access to your Personal Data to staff who have a genuine business need to know.

We also take reasonable steps to protect your Personal Data from loss or destruction and have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach in the unlikely event that one occurs.

Contacting you

We may contact you by telephone, e-mail or in writing for general operational purposes including to validate your identity. If you apply to borrow money from LoanBook, or to use any of our services, we might contact you to request further Personal Data for our underwriting process and will send regular emails to update you on the progress of your loan application. If your loan is approved and you accept the loan, we will then contact you at regular intervals to keep you informed about your loan, particularly if you miss any payments.

Changes to this Privacy Notice

We will update this Privacy Notice from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of our service after any such updates take effect will constitute acknowledgement and acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Notice, you may cancel your use of our service.

Complaints

If you have a concern about the way we process your personal information, please send an email to our Data Protection Officer stating your name, contact address such as your email and phone number, your account number, username, what you think we have done wrong, and all relevant information and evidence in support of the complaint. While we try to respond as promptly as possible, resolution time will vary depending on the nature of the complaint. You will be notified of the outcome of your complaint as well as any action taken.

If you are unhappy with the outcome of your complaint or how the complaint was handled, then you may appeal by writing to our head of legal at legal@loanbookng.com outlining your reasons.

If you remain unhappy after the appeal process, you may forward your complaint to the Nigerian Data Protection Bureau at https://app.ndpb.gov.ng/BreachReports/Create