This Privacy Policy explains how CrediSurge Lending Limited (“CrediSurge,” “we,” “us,” “our”) collects, uses, discloses, and protects your personal data when you visit our website or use our loan services.
1. Information We Collect
We may collect the following types of personal data to process your loan application and provide our services:
- Identity Data: full name, date of birth, BVN, NIN, government-issued ID details, and photograph.
- Contact Data: email address, phone number, residential address.
- Financial Data: bank account details, bank statements, income information, credit history, transaction records.
- Technical Data: IP address, browser type, device information, operating system, and usage data collected automatically when you visit our website or use our app.
- Communication Data: records of your communications with us, including call logs, chat transcripts, and email correspondence.
2. How We Use Your Information
We use your personal data for the following purposes:
- To process your loan application and manage your account.
- To verify your identity through BVN and other KYC checks as required by Lagos State money lender regulations.
- To assess your creditworthiness and determine loan eligibility, amount, and terms.
- To disburse loan funds to your bank account and process repayments.
- To communicate with you about your application, repayment schedule, and account status.
- To comply with legal and regulatory obligations under Nigerian law, including anti-money laundering (AML) requirements.
- To detect and prevent fraud, default, and other illegal activities.
- To improve our services and develop new products.
3. Legal Basis for Processing
We process your personal data based on the following legal grounds under the Nigeria Data Protection Regulation (NDPR):
- Consent: You have given clear consent for us to process your personal data for specific purposes, such as credit checks.
- Contract: Processing is necessary for the performance of a loan agreement with you.
- Legal Obligation: Processing is necessary for compliance with legal obligations, including CBN directives, Lagos State money lender regulations, and AML/CFT requirements.
- Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, network security, and business analytics, provided your interests and fundamental rights do not override those interests.
4. Data Sharing and Disclosure
We may share your personal data with the following categories of third parties:
- Credit Bureaus: CRC Credit Bureau, CreditRegistry, FirstCentral — for credit assessment and reporting. Your loan performance may affect your credit score.
- Payment Processors: Banks and payment service providers for loan disbursement and repayment processing.
- Identity Verification Services: KYC/AML service providers for identity verification and fraud prevention.
- Regulatory Authorities: Lagos State Ministry of Home Affairs, CBN, FCCPC, NDPC, and other applicable regulatory bodies as required by law.
- Debt Collection Agencies: In the event of loan default, we may engage licensed debt collection agencies to recover outstanding amounts.
- Professional Advisors: Lawyers, auditors, and insurers who provide professional services to us.
We do not sell your personal data to third parties.
5. Data Retention
We retain your personal data for as long as necessary to fulfil the purposes for which it was collected. Specifically:
- Loan and account data: retained for six (6) years after the loan is fully repaid or the account is closed, in compliance with Nigerian regulatory requirements.
- Identification and KYC data: retained for the duration of our relationship and for the period required by applicable laws.
- Transaction records: retained for audit and compliance purposes.
After the retention period, your data will be securely deleted or anonymised.
6. Your Rights
Under the Nigeria Data Protection Regulation (NDPR) and other applicable laws, you have the following rights:
- Right of Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your personal data, subject to legal retention obligations.
- Right to Restrict Processing: Request restriction of processing in certain circumstances.
- Right to Data Portability: Request transfer of your data to another service provider in a structured, commonly used format.
- Right to Object: Object to processing based on legitimate interests, including direct marketing.
- Right to Withdraw Consent: Withdraw consent at any time where we are relying on consent to process your data.
To exercise any of these rights, please contact us at support@credisurge.ng. We will respond to your request within one month.
7. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:
- Encryption of data in transit (TLS 1.3) and at rest (AES-256).
- Access controls and authentication mechanisms.
- Regular security audits and vulnerability assessments.
- Staff training on data protection and confidentiality.
- Incident response procedures for data breaches.
8. Credit Reporting
We report loan performance to licensed credit bureaus in Nigeria. This means:
- Your loan application and repayment history may be shared with credit bureaus.
- Timely repayments can positively impact your credit score.
- Default or late payments may negatively affect your credit score and be recorded in your credit history.
- You have the right to request a copy of your credit report from the credit bureau.
9. Cookies and Tracking
Our website and app use essential cookies and similar technologies to ensure proper functionality. We do not use tracking or advertising cookies. You can configure your browser to refuse cookies, but this may affect the functionality of our website. We also collect basic usage analytics to improve our services.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will notify you of any material changes by posting the updated policy on our website and updating the “Last updated” date at the top of this page. We encourage you to review this policy periodically.
11. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:
Email: support@credisurge.ng
Address: Lagos, Nigeria
12. Complaints
If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or the Lagos State Consumer Protection Agency.