Privacy Policy

Your privacy and data security

Last Updated: January 1, 2025

Table of Contents

Introduction

Welcome to SPEP MULTIPURPOSE ENTERPRISE ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our loan application and related services. We are committed to protecting your privacy and complying with the Nigeria Data Protection Regulation (NDPR) and other applicable laws.

By using our services, you consent to the data practices described in this policy. Please read this policy carefully to understand our views and practices regarding your personal data.

1. Information We Collect

We collect several types of information from and about users of our services, including:

1.1 Personal Identification Information

  • Full name (as on government ID)
  • Date of birth
  • Phone number
  • Email address
  • Home/Office address
  • BVN (Bank Verification Number)
  • NIN (National Identification Number)
  • Government-issued ID details (National ID, Voter's Card, Driver's License, International Passport)

1.2 Financial Information

  • Bank account details (account number, bank name)
  • ATM card information (for auto-debit purposes - tokenized, not stored)
  • Transaction history
  • Credit history and loan repayment behavior
  • Income and employment information

1.3 Technical Information

  • Device information (IP address, device ID, operating system)
  • Browser type and version
  • Usage data (pages visited, time spent, clicks)
  • Location data (with your consent)
  • Mobile network information

1.4 Verification Information

  • Selfie/Photograph (for identity verification)
  • Utility bills (for address verification)
  • Employment verification documents
  • Bank statements

2. How We Use Your Information

We use the information we collect for various purposes, including:

  • Loan Processing: To evaluate loan applications, determine creditworthiness, and process disbursements
  • Identity Verification: To verify your identity using BVN, NIN, and other government-issued IDs
  • Risk Assessment: To assess credit risk and prevent fraud
  • Repayment Processing: To process loan repayments via auto-debit or other payment methods
  • Communication: To send loan approvals, repayment reminders, and important updates via SMS, email, or push notifications
  • Customer Support: To respond to your inquiries and provide assistance
  • Service Improvement: To analyze usage patterns and improve our services
  • Legal Compliance: To comply with regulatory requirements and legal obligations
  • Marketing: To send promotional offers (you can opt-out anytime)

3. Information Sharing & Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Third-Party Service Providers

We share information with trusted third parties who assist us in operating our services:

  • Paystack: For payment processing, BVN verification, and bank account verification
  • Termii: For SMS notifications and communications
  • Credit Bureaus: To report and check credit history (CRC Credit Bureau, CR Services, etc.)
  • Identity Verification Services: To verify government-issued IDs
  • Cloud Hosting Providers: To store and process data securely

3.2 Legal Requirements

We may disclose your information if required by law, court order, or government regulation, including but not limited to:

  • Central Bank of Nigeria (CBN) regulations
  • Nigeria Data Protection Regulation (NDPR) compliance
  • Anti-money laundering (AML) and counter-terrorism financing (CFT) laws
  • Law enforcement agencies with proper legal documentation

3.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your information may be transferred to the new owner.

4. Data Security

We implement robust security measures to protect your information:

  • Encryption: 256-bit SSL/TLS encryption for all data transmission
  • Secure Storage: AES-256 encryption for stored sensitive data
  • Access Control: Strict role-based access controls and multi-factor authentication
  • Regular Audits: Security audits and vulnerability assessments
  • Tokenization: Card details are tokenized, never stored in raw format
  • Data Minimization: We only collect data necessary for our services
  • Employee Training: Regular data protection and security training for staff

While we strive to protect your data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

5. BVN & NIN Information

Your BVN (Bank Verification Number) and NIN (National Identification Number) are sensitive personal data. We collect and process them for:

  • Identity verification and fraud prevention
  • Credit assessment and loan underwriting
  • Compliance with CBN and NIMC regulations
  • Account linking and validation

Important: We are NDPR compliant and have obtained necessary approvals from NIMC for NIN verification. We never store your complete BVN or NIN in plain text and use secure APIs for verification.

6. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience:

  • Essential Cookies: Required for basic site functionality
  • Preference Cookies: Remember your settings and preferences
  • Analytics Cookies: Help us understand how users interact with our site
  • Security Cookies: Detect and prevent fraudulent activity

You can control cookies through your browser settings. However, disabling cookies may affect some functionality.

7. Your Rights

Under the Nigeria Data Protection Regulation (NDPR), you have the following rights:

  • Right to Access: Request a copy of your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure: Request deletion of your data (subject to legal retention requirements)
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a structured format
  • Right to Object: Object to certain data processing activities
  • Right to Withdraw Consent: Withdraw consent at any time
  • Right to Lodge Complaint: File a complaint with NITDA

To exercise these rights, contact our Data Protection Officer at dpo@spepenterprise.com

8. Data Retention

We retain your personal data for as long as necessary to:

  • Provide our services and fulfill loan agreements
  • Comply with legal obligations (typically 5-7 years as required by CBN)
  • Resolve disputes and enforce agreements
  • Prevent fraud and abuse

After the retention period, your data will be securely deleted or anonymized.

9. Children's Privacy

Our services are strictly for individuals aged 18 years and above. We do not knowingly collect data from minors. If we discover that we have collected data from a minor, we will delete it immediately.

10. Changes to This Privacy Policy

We may update this policy periodically. We will notify you of significant changes through:

  • Email notification to registered users
  • Prominent notice on our website
  • SMS notification for critical changes

The "Last Updated" date at the top indicates when changes were made. Your continued use of our services constitutes acceptance of the updated policy.

Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

  • Data Protection Officer: dpo@spepenterprise.com
  • Customer Support: support@spepenterprise.com
  • Phone: +234 123 456 7890
  • Address: SPEP Multipurpose Enterprise, Lagos, Nigeria
  • Compliance Officer: compliance@spepenterprise.com