Privacy Policy

This Privacy Policy was prepared to protect and maintain the privacy of Product Users. The Product was created, owned and operated by FLOODLIGHTS TECHNOLOGY LTD (“FLOODLIGHTS TECHNOLOGY”, “SmartNaira”, “we”, “us”, or “our”). Users are requested to read and understand this Privacy Policy carefully before using the Service. By i) clicking or checking or otherwise indicating the User's intent to accept or agree to this Privacy Policy, and/or ii) accessing and using the Services on the Product, the User acknowledges that he has read, understood and agreed to every provision written in this Privacy Policy and the terms of use of the Product. The Privacy Policy also stipulates the actions in which SmartNaira obtains, collects, processes, analyses, stores, rectifies and updates, displays, announces, transfers, disseminates, discloses, deletes, destroys personal information. By visiting or using the Services on the Product the User is deemed to have read, and agrees to the acquisition, processing and analysis, storage, rectification, updates, display, announcement, transfer, dissemination, disclosure, deletion, and destruction of User's Information in accordance with the Privacy Policy. This Product is designed and intended for use by persons residing in Nigeria.

1.General Provisions

SmartNaira shall collect from any user and to what degree, extent we may use, process and transfer the information when you register, access or use our Mobile App (SmartNaira), Website (https://www.smartnaira.app), products, and services (collectively, the “Services”). The Service provides users with the opportunity to apply for and be granted small loans subject to the terms and conditions agreed upon by both parties. By visiting and/or using our Service, you are accepting and consenting to the practices described in this Privacy Policy.

2.Definitions

In addition to those specified elsewhere in this Privacy Policy, the following terms will have the definitions, meanings and interpretations specified below:

• 2.1 "Personal Information/Data" means shall include all data, information and documents, whether electronic or non-electronic, of or concerning the User and/or related parties of the User (including but not limited to the User's family, associates, employees, companies or service providers, if required for emergency contact or for other legitimate reasons) that SmartNaira receives or accesses from the User or third parties, submitted, provided or disclosed by the User to SmartNaira, according to the consent of the User concerned and stored and managed in connection with the provision of Services on the Product and in the context of the utilization of Services on the Product by the User.

• 2.2 "User" means any person registering SmartNaira’s Application and/or using services provided by us.

• 2.3 "Terms and Conditions" are the terms and conditions for using the Product set by the Provider, as accessible and have been understood and approved by Users when registering through the Product.

• 2.4 User’s Information means includes i) User’s “Personal Information/Data” and ii) other information/data mentioned in this Privacy Policy.

• 2.5 "Law" means all laws and regulations and their implementing regulations, decrees or policies that are in effect and have legal force including regulations, regional regulations and other derivative laws, requirements and guidelines in the Federal Republic of Nigeria

• 2.6 "Cookies" means a type of file containing information sent by a website/application to the computer hard disk of every visitor who visits the website/application for the purpose of recording certain information by the computer, such as internet protocol (IP) addresses, browser type and operating system (OS), day, date and time when visitors access the website and data from small-click server streams to monitor website/application access activities and website/application addresses accessed by Users. Cookies function to remember important information that will help in using the website/application, if the User decides to visit the website/application again in the future.

• 2.7 "You", with grammatical variations and cognate expressions, refers to any other person using the Product and/or the Services whether or not registered on the Product.

• 2.8 “Process/Processing” means the actions includes:

  • a.acquisition and collection.

  • b.processing and analysis.

  • c.storage; rectification and updates.

  • d.appearance, announcement, transfer, distribution or disclosure; and/or

  • e.deletion or destruction.

3.Applicability and Consent

• 3.1 This Privacy Agreement is compiled and shall become an integral part of the terms and conditions for using Product (“Terms and Conditions”). Words or terms that use capital letters used in this Privacy Policy, unless otherwise specified in this Privacy Policy or if the context otherwise requires, will have the meaning as specified in the Terms and Conditions. Words in the singular are also in the plural and vice versa. By accessing the Product and/or providing Personal Information to Us, You have read and understood Our Privacy Policy and consent to the Processing of Your Personal Information in accordance with this Privacy Policy.

• 3.2This Privacy Policy shall legally bind Users from the date:

  • a. The User clicks or checks or otherwise indicates the User's intent to accept or agree to this Privacy Policy; and/or

  • b. Users access and use the Service and/or Product.

  • c. For avoidance of doubts, if this Privacy Policy is amended during Users’ accessing and using of the Service and/or Product, by continuing to access and use the Service and/or Product, Users agree to the amended Privacy Policy, and the amended Privacy Policy shall legally bind Users from Users’ first access and use of the Service and/or Product after the amendment.

• 3.3 This Privacy Policy continues to apply as long as:

  • a. The registered Users are registered as Users on the Product.

  • b. The registered Users still has obligations, financial responsibilities, debts or similar matters to the the Loan Agreement; and/or

  • c. The registered Users are still in the process of submitting an application for obtaining a loan along with an assessment of it by SmartNaira or any third party cooperated by SmartNaira.

  • d. The registered Users understand that we may share your Personal Information with the authorized government agencies and/or other institutions that may be appointed by government authorities. You agree and acknowledge that the retention of your Personal Information by the relevant government agencies and/or other institutions will follow the respective parties’ policies regarding data retention.

  • e. The registered Users understand that this Privacy Policy is still valid and binding to Users as long as is necessary for the purposes set out herein.

4. Legal Basis for Data Processing

Pursuant to the applicable laws and regulations, We process your Personal Data based on one or more of the following legal grounds:

• 4.1 Consent: processing based on your explicit consent for specific purposes.

• 4.2 Performance of a Contract: processing necessary to fulfill Users’ and our obligations under the agreement and other relevant documents.

• 4.3 SmartNaira’s Legal Obligation: processing necessary to comply with our legal obligations.

• 4.4 Legitimate Interests: processing necessary for our legitimate interests or those of third parties, provided your fundamental rights are not overridden.

• 4.5 Interest protection: processing based on the vital interest of personal data subject.

5. Information We Collect

• 5.1 To provide our Services, assess your creditworthiness, prevent fraud, and comply with regulatory requirements, we collect information directly from you, from your device (with your explicit permission), and from third-party sources. Below we detail each category of information, the exact data collected, and the purpose of collection.

• 5.2 Collection of Personal Data as data controller shall be conducted by SmartNaira or SmartNaira’s cooperative third parties from data subjects directly or indirectly after SmartNaira owns the legal basis mentioned in Article 4 regarding Legal Basis for Data Processing and SmartNaira shall collect in compliance to the applicable laws and regulations.

• 5.3 Collection of information of data subject (including but not limited to User) shall be conducted by SmartNaira or SmartNaira’s cooperative third parties from data subjects directly or indirectly after SmartNaira obtains prior consent unless required or exempted by applicable laws and regulations and SmartNaira shall collect in compliance to the applicable laws and regulations.

• 5.4 Information You Provide to Us:

  • a. Personal Identity Information

    • Data Collected: Full name, Nigerian resident identity card number, passport number (if applicable), date of birth, gender, marital status, email address, mobile phone number, home address.

    • Purpose: To verify your identity, comply with “Know Your Customer” (KYC) requirements, and communicate with you regarding your account and loan.

  • b. Employment and Financial Information

    • Data Collected: Company name, company address, job title, occupation, length of employment, monthly income, guarantor’s name and phone number, bank account details.

    • Purpose: To assess your repayment capacity, verify the stability of your income, and transfer loan funds to your designated bank account.

  • c. Biometric Data

    • Data Collected: Selfie photograph, facial recognition data, ID card image.

    • Purpose: To verify that the applicant is the true owner of the provided identity documents and to prevent impersonation or identity fraud. This processing is strictly limited to identity verification in compliance with Google Play biometric policies, and will not be used for advertising or marketing.

  • d. Emergency Contacts

    • Data Collected: Name, relationship to you, and phone number of your emergency contacts.

    • Purpose: To confirm your identity, assist in repayment communication if we cannot reach you directly, and comply with risk management requirements. You represent and warrant that you have obtained the consent of your emergency contacts before providing their information.

• 5.5 Information We Collect From Your Device (with your explicit consent when using the App):

  • a. SMS Data

    With your explicit permission, we will only access financial related message of your SMS inbox to assess your creditworthiness and detect fraud. The collection is strictly controlled under the following rules:

    • Scope of Collection:

      • a. Timeframe: Messages from the last 6 months only.

      • b. Quantity: Maximum of 2,000 messages.

      • c. Data Points: Sender ID, message body, and timestamp.

      • d. Access is limited to financially relevant messages only.

    • Only SMS with financial related Keywords will be Collected. Examples of financial related keywords:

      • a. loan

      • b. repayment / repay

      • c. overdue

      • d. default

      • e. credit

      • f. debit / DR

      • g. credit alert / CR

      • h. salary / allowance / allowee

      • i. interest

      • j. transfer / funds transfer

      • k. balance

      • l. cash / cash out

      • m. payment due

      • n. due date

      • o. penalty

      • p. other keywords identified important to financial conditions of user

    • Types of Messages Explicitly Excluded: We do not collect or analyze SMS messages unrelated to financial activity. The following categories are screened out by key words and excluded from processing:

      a. Education-related messages (e.g., school fee).
      b. Travel and ticketing (e.g., flight bookings).
      c. E-commerce platforms (e.g., Jumia).
      d. Shopping and order confirmations (e.g., order).
      e. Entertainment and lifestyle (e.g., cinema).
      f. Streaming and subscription services (e.g., Spotify).
      g. Ride-hailing and delivery services (e.g., Uber).
      h. Fitness and lifestyle services (e.g., gym, salons).
      i. Sender whose numbers begin with 312, 303, 131, 127, or 323.

    • Purpose of Collection

      a. To evaluate your eligibility to use our service.
      b. To confirm income and repayment capacity.
      c. To detect existing loans or repayment obligations.
      d. To prevent fraud, over-indebtedness, or multiple borrowing

    • Data Protection: All SMS data is transmitted using SSL encryption transferred to SmartNaira server(hppts://app.smartnaira.top/). Collected SMS are analyzed for the purposes described above and deleted thereafter. You can choose to withdraw the consent on your device. We do not share your SMS data with any third party without your consent.

  • b. Installed Applications (Financial and Fraud-Related Only)

  • Data Collected: When you use the SmartNaira App, we may collect information about certain applications installed on your device that are financial or fraud related. The data collected includes:

    a. Application package name
    b. Version number
    c. Installer source
    d. Installation date
    e. Last update date

  • Filtering Strategy: To ensure that we collect only financial and fraud-related applications, we apply multiple filtering rules:

    a. Inclusion filter: We only collect applications whose names or package descriptions contain financial or risk-related keywords such as loan, credit, bank, wallet, cash, finance, lending.
    b. Exclusion filter: We explicitly exclude lifestyle and non-financial applications, such as those related to education (e.g., school apps), travel (e.g., flights, ride-hailing), e-commerce (e.g., Jumia, order apps), entertainment (e.g., cinema, streaming apps like Spotify), food delivery/transport (e.g., Uber), or fitness (e.g., gym apps).
    c. Technical filter: Our system uses internal code logic to filter out application categories not relevant to financial risk analysis. This ensures we never collect your entire app list.

  • Purpose: The information is collected solely for:

    a. Credit risk analysis
    b. Fraud identification
    c. Preventing over-indebtedness
    d. Protecting your account and funds security

  • Data Protection:

    a. All collected information is securely transmitted using SSL encryption to SmartNaira server(hppts://app.smartnaira.top/).
    b. The information is analyzed only for the purposes described above and deleted afterwards.
    c. We will never share this data with third parties without your explicit consent.
    d. You may withdraw your consent at any time through your device settings, which will stop further collection.

  • c. Device Information

    • Data Collected: Device brand/model; operating system version; screen resolution; language/region; time zone; battery state; device identifiers (as permitted by policy); integrity indicators (e.g., root/jailbreak/emulator status).

    • Purpose: Fraud detection; device integrity checks; account security.

    • Data Protection: All data is transmitted using SSL encryption transferred to SmartNaira server(hppts://app.smartnaira.top/). Collected data are analyzed for the purposes described above and deleted thereafter. You can choose to withdraw the consent on your device. We do not share your data with any third party without your consent.

  • d. Location (Approximate/Coarse)

    • Data Collected: Coarse location at key loan events (application, disbursement, repayment).
    • Purpose: Service-area eligibility; geolocation anomaly detection (anti-fraud). We do not track your location in the background.
    • Data Protection: All data is transmitted using SSL encryption transferred to SmartNaira server(hppts://app.smartnaira.top/). Collected data are analyzed for the purposes described above and deleted thereafter. You can choose to withdraw the consent on your device. We do not share your data with any third party without your consent.

  • e. Wi-Fi Network Information

    • Data Collected: Current network SSID and BSSID at critical verification steps.
    • Purpose: Evaluate network risk (e.g., public/spoofed networks) to prevent fraud.
    • Data Protection: All data is transmitted using SSL encryption transferred to SmartNaira server(hppts://app.smartnaira.top/). Collected data are analyzed for the purposes described above and deleted thereafter. You can choose to withdraw the consent on your device. We do not share your data with any third party without your consent.

  • f. Camera and photos

    • Data Collected: Live camera capture for selfie and ID document images.
    • Purpose: This information is used solely for identity verification and fraud prevention as part of our credit review and KYC (Know Your Customer) process.
    • Data Protection: All photo data is transmitted using SSL encryption transferred to SmartNaira server(hppts://app.smartnaira.top/). Collected data are analyzed for the purposes described above and deleted thereafter. You can choose to withdraw the consent on your device. We do not share your data with any third party without your consent.

• 5.6 Information From Third Parties

  a. Credit Bureaus and Financial Institutions

  • Data Collected: Credit score/history; outstanding loans; repayment records; other bureau-reported attributes.
  • Purpose: Creditworthiness assessment; prevent over-indebtedness; regulatory compliance.

  b. Public Records and Official Databases

  • Data Collected: Identity and status information that is lawfully available in public/government registries.
  • Purpose: Identity validation; document verification; compliance with applicable laws.

• 5.7 The User acknowledge that the relevancy of collecting the type of Personal Data as mentioned in this article is for processing the User’ Personal Data as described in Article 7 on Disclosure of Information We Collect, Article 8 on Purpose or any article herein.

6. How We Collect Information

• 6.1 SmartNaira may collect Personal Data directly from you or indirectly from other external sources to enable us to fulfill our mandate as a Product to process your request and to comply regulatory requirements. We may collect this Personal Data through:

  • a. User registration: users disclose its Personal Data to us during registration in SmartNaira;

  • b. Collected by Product: Information automatically collected: i) when you use our Product, including technical data such as IP address, usage activity and Transaction Data; ii) when the User makes payments in our Product, including SmartNaira, the information generated from the use of the SmartNaira Product, which is automatically collected from the User; iii) when the User interacts with the SmartNaira Product, and/or iv) other information accessed through the API;

  • c. Collection from SmartNaira’s third parties: information obtained from other SmartNaira’s third parties in compliance with applicable laws and regulations.

  • d. Collection from other SmartNaira’s registered Users.

  • e. Publicly available source as permitted by applicable laws and regulations.

• 6.2 Therefore, SmartNaira will request access permission to your camera, location, and microphone.

• 6.3 SmartNaira may collect and process access information on the User’s approximate location, camera, and microphone and the Personal Data when the User uses the Product with the prior User’s permission, provided that:

  • a. SmartNaira shall be prohibited from accessing and reading images, contacts of Users, external storage, fine location, and/or videos.

  • b. SmartNaira shall not access, collect, use and share the Personal Data and the Access acquired through the Product for the purpose other than Article 7 on Disclosure of Information We Collect and Article 8 on Purpose unless otherwise required or exempted by applicable laws and regulations in compliance with the Google Policy amended, changed and modified from time to time.

  • c. SmartNaira may also transfer data as necessary to service providers or for legal reasons such as complying with a valid governmental order, request, court decision, Governing Law, or as part of a merger or acquisition with proper notification to Users.

7. Disclosure of Information We Collect

SmartNaira is committing to keeping your information confidential. However, you agree that SmartNaira may disclose, transfer and/or give access to your Information to parties that we deem necessary in connection with our Services and/or for regulatory compliance purposes for their Processing (if applicable) in connection with one or more purposes as set out in this Privacy Policy and in accordance with applicable laws and regulations, including but not limited to:

• 7.1 directors, officers, employees and/or affiliates of SmartNaira;

• 7.2 Authorised third party service providers with whom SmartNaira works, including:

  a. Payment service providers.
  b. Electronic signature service providers.
  c. electronic know-your-customer service providers.
  d. Messaging-as-a-Service API providers.
  e. credit scoring service providers.
  f. anti-fraud & risk control provider.
  g. any aggregator or other financial digital innovation provider.
  h. loan application/credit history provider.
  i. AI communication provider.
  j. Advertising provider.
  k. web and mobile analytics provider.
  l. Message/call channeling service provider; and/or
  m. other relevant and applicable service in compliance with Nigeria laws and regulations that will help SmartNaira’s to improve its Service and Product.

• 7.3 Banks.

• 7.4 Third-party money lenders.

• 7.5 Business partner for channeling cooperation, joint marketing cooperation and/or other parties relevant to our business operations.

• 7.6 Courts, prosecutors, police, other government institutions either at the initiative of SmartNaira or as required by legal provisions and regulations, directives, instructions or policies of government institutions or government officials.

• 7.7 Any member of Our group (which means Our subsidiaries, Our affiliates, Our ultimate holding company and its subsidiaries) from time to time for one or more of the purposes.

• 7.8 The Authorized government institution under Nigerian law.

• 7.9 Other registered Users of SmartNaira when checking updates of Your Personal Information or alternative Personal Information in our Product; and

• 7.10 Any party authorized and/or approved by you.

We may need to disclose Personal Data to third party service providers, agents, our affiliated companies, and/or other third parties located outside the territory of the Republic of Nigeria. Nonetheless, such third-party service providers, agents and/or affiliates or related companies and/or other third parties shall only manage and/or utilize Personal Data in connection with one or more purposes as set out in this Privacy Policy and in accordance with applicable laws and regulations.

8.Purpose

• 8.1 User hereby agree that SmartNaira is entitled to request, obtain, collect, process, analyze, rectify, update, store, disclose, display, announce, transfer, disclosure and/or use one or more information we collect of data subject, in the framework of or related to for one or more of the below purpose as permitted by laws and regulation is as follows:

  a. Sending one of User’s Information to the relevant third party for the purpose of providing SmartNaira’s service to User, including but not limited to: i) registration and credit scoring; ii) OCR provider; iii) electronic signature provider as disclosed in Article 7;
  b. Assessment, analysis, verification, validation or examination of (i) application registration; (ii) a loan application and line of credit; (ii) the process or application for registration; and/or (iii) User profile, by using any methods from SmartNaira;
  c. Carrying out statistical analysis, credit, risk and anti-money laundering screening, conduct credit checks, reviews and other backgrounds checks and/or risk profile and keep history of Your credit for current and future reference.
  d. Comparing information and verify with the authorized third-party service provider whom we may cooperate with to ensure that the information is accurate.
  e. Contacting you to determine the availability of the contacts You provide and the fraud-risk of Your application.
  f. Requesting the update of User’s Personal Information or alternative Personal Information from User, third parties or other Users.
  g. Monitoring, detecting, prevent, verify and investigate suspicious transactions or transactions that are indicated to contain elements of fraud, crimes or violations of the Terms and Conditions or applicable legal provisions, as well as taking necessary actions as a follow-up to the results of monitoring or investigating such transactions.
  h. Helping us detect and fight abuse, malicious acts, fraud, spam, and illegal activity on the Product.
  i. Conducting investigations under the prevailing laws including anti-money laundering and prevention of terrorist financing in the financial services sector.
  j. Creating, manage, train and/or develop credit assessment models, including but not limited to artificial intelligence or machine learning models and algorithms in connection with the services and products of SmartNaira or any other cooperative/related third-parties.
  k. Calling and/or sending you our marketing and/or promotional Materials from time to time through short message service (SMS), Whatsapp (WA), email, including calling the registered Users by AI Robot;
  l. Sending newsletters/information from/about the service/products of us, our related companies and any third parties that may be of interest to you;
  m. Sharing Information to cooperative/related third parties for them to promote and/ or provide their products to you;
  n. Introducing or recommending third-party credit Products and/or third-party money lenders to users thus providing suitable or comprehensive services;
  o. Evaluating the effectiveness of the marketing of the Product/cooperative or related third parties, including for periodic checks, for marketing research, evaluation, academic studies, analysis and product development. This allows Us to understand and analyze Your preferences and needs, and develop new features, products and services;
  p. Sending any related loan reminder in Product to User;
  q. Checking User’s emergency contact for the confirmation of User’s whereabouts;
  r. Conducting audit the downloading of data from the Product;
  s. Identifying You when You contact Us or visit the Product;
  t. Responding and processing your inquiries, requests, complaints, and notify any change on Product and services;
  u. Fulfillment of SmartNaira's rights and obligations based on legal provisions and statutory regulations including but not limited to relevant laws and regulation on Anti-Money Laundering and Counter Financing of Terrorism, Funding Agreements and/or Loan Agreements;
  v. Implementation and supervision of the Loan Agreement;
  w. Implementation of SmartNaira's business and operational activities from time to time in good faith;
  x. Survey, research, evaluation and/or development of products or services by SmartNaira or related interested parties;
  y. Processing, administering, managing and dealing with the Service or products that any third-party provided to SmartNaira; and
  z. Use Your Personal Information for any other purpose to which You have provided consent.

  We may request, obtain, collect, process, analyze, rectify, update, store, disclose, display, announce, transfer, disclosure and/or use Your Information for other purposes that do not appear above. However, We will notify You of such other purpose at the time of obtaining Your consent, unless processing of Your Information without Your consent is permitted by any applicable law.

• 8.2 The User hereby grants SmartNaira an irrevocable, non-exclusive, royalty-free, transferable permission to use any information and/or content on the SmartNaira Product that the User installs, stores, uses, and/or inputs on or in connection with the SmartNaira Product (“Permission”) during using or enjoying SmartNaira Product.

• 8.3 This Permission shall continue to operate and only end if the User requests on withdrawal consent to SmartNaira in writing for the purpose of deleting User information and/or content on the SmartNaira Product, provided that such request will follow to SmartNaira’s internal policy relating to delete User information. Besides, it is needed to grant us a permission to ues notification and calendar fuctions of your device for the purpose of pushing notifications when the status of your loan changes and creating a loan repayment reminder on your device's calendar. Futher more, we need identify and analyze the nearby devices of yours with the help of collectting bluetooth and network connection data for the purpose of detecting suspicious activities(e.g, using the device in an unfamiliar network environment may imply that you are not operating it yourself), which is also agreed by the user hereby.

• 8.4 If Users do not agree with Us using Your Personal Information for such purposes, Users can send a written request to SmartNaira. Please note should You wish to object the usage of Your Personal Information in this way, We may not be able to continue to offer You Our products and services, in which case We may need to terminate Our relationship in order to fulfill Your request.

9. Cookies Policy

• 9.1 SmartNaira uses Cookies for various purposes such as when the User shall visit the SmartNaira Product website again, count the number of Users, and remember Users especially if the User uses services on the SmartNaira Product.

• 9.2 When Users access or use the SmartNaira Product, SmartNaira automatically shall use Cookies.

• 9.3 If Cookies are enabled, Cookies shall record a small amount of data on the SmartNaira Product website visited by the User, and Cookies shall help SmartNaira to track the features that the User is most interested in and the content that the User has visited before.

• 9.4 When the User visits SmartNaira's website at a later time, Cookies shall make it easier for SmartNaira to customize the SmartNaira Product content to meet User's needs.

• 9.5 If the User does not want to send "Cookies" information about them, the User can disable User Cookies in the web browser function, by using "Options" in the web browser to choose not to receive Cookies on the computer hard disk or choose to request permission on the computer when receiving Cookies. You may not benefit from some Services on the Product if Cookies are deleted or prevented from being installed on your device.

• 9.6 Click "Help" to find out more about the method of accepting specified Cookies. If the User adjusts the User's computer settings which results in rejection of Cookies on the User's computer, then the User cannot enjoy all the facilities.

• 9.7 Use of Cookies by many other companies is subject to their own privacy policies, and not this Privacy Policy. Advertisers or other companies do not have access to SmartNaira's Cookies.

10. Security of Personal Information

• 10.1 SmartNaira appreciates the protection of User privacy and SmartNaira maintains the confidentiality of Information and any information related to User's Account based on this Privacy Policy by:

  a. shall not disclose any information except as provided in Article 7 on Disclosure of Information We Collect and Article 8 on Purpose of this Privacy Policy;
  b. guard technology products to prevent unauthorized computer or network access;
  c. limit SmartNaira employees who have access to User data;
  d. carry out technical security efforts to secure the storage of information; and
  e. continuously monitor that User Information is protected and there are safeguards in place to protect Information.

• 10.2 SmartNaira shall take all reasonable steps and actions to prevent loss, misuse or alteration of User's Personal Information without permission by unauthorized parties.

• 10.3 Regardless of SmartNaira's steps and precautions, unauthorized entry or use, as well as hardware or software failure, may occur and compromise the security of User's Personal Information. In connection with these matters SmartNaira hereby provides a disclaimer that, to the fullest extent permitted by law, any direct or indirect responsibility or liability arising from or in connection with any loss, theft, or unauthorized access, taking, use, disclosure, copying, modifying, deleting or similar actions regarding Personal Information provided by Users to SmartNaira.

• 10.4 When registering on the Product, the User is asked to create the User's own personal password. The user is responsible for maintaining the confidentiality of the password. Users are requested not to share User passwords with any party.

• 10.5 Despite Our measures and precautions, unauthorized entry or use, as well as hardware or software failures, may occur and compromise the security of Your Personal Data. In connection with these matters We hereby provide a disclaimer that, we cannot guarantee that the internet is 100% secure. Users’ transmission of Personal Data to and from our Funding Services is at your own risk. Therefore, We recommend that You should only access the Product in a secure and protected internet environment.

• 10.6 Users understand that we may share your Personal Data with authorized government agencies and/or other agencies that may be designated by government authorities. You agree and acknowledge that the storage of Your Personal Data by the relevant government agencies and/or other agencies will follow each party's policies regarding data storage.

• 10.7 Users need to pay attention that messages sent via an internet connection cannot be fully guaranteed for security and can be withheld, lost or changed. SmartNaira shall not be responsible for messages that are lost, modified by third parties, or withheld and SmartNaira is not materially responsible to Users or anyone for damage or other matters in connection with messages sent by Users to SmartNaira or by SmartNaira to Users via an internet connection.

11. Failure to Secure Personal Data

• 11.1 SmartNaira is committed to safeguarding Your Personal Data and complying with the provisions of applicable laws and regulations.

• 11.2 In the event of a failure to protect Personal Data on the Product or when we become aware of it from a third party, we will make reasonable efforts to notify in writing via electronic mail to You with and provide the reasons or causes of the failure to protect your Personal Data.

12.Change, Return and Destruction of Personal Data

• 12.1 All Personal Information (including past or update Personal Information) and other Information provided by the User and/or received by SmartNaira in accordance with the Privacy Policy is stored securely in the territory of the Republic of Nigeria and if such Personal Information is sent outside the territory of the Republic of Nigeria, the delivery shall be carried out in accordance with the terms and conditions of the applicable laws and regulations.

• 12.2 SmartNaira will ensure all reasonable steps and measures to prevent the destruction, loss, misuse, disclosure, access or unauthorized alteration of your Personal Data by unauthorized parties. We protect your Personal Data by: (i) restricting access to Personal Data; (ii) maintaining and using technology products, including firewalls, and other security procedures to prevent unauthorized computer access and network access; and (iii) other reasonable cybersecurity measures.

• 12.3 SmartNaira shall also take reasonable steps to protect User data during transfer and storage; steps may include obtaining User consent, implementing contractual protections, and using other legally recognized transfer mechanisms.

13. Change, Return and Destruction of Personal Data

• 13.1 User's Personal Information can be destroyed at the request of the User, unless SmartNaira is required to store it in accordance with statutory provisions.

• 13.2 Destruction of Personal Information includes removing part or all of the documents related to User Personal Information that SmartNaira keeps so that the Personal Information cannot be displayed again in SmartNaira's electronic system unless the User provides new Personal Information to SmartNaira.

• 13.3 SmartNaira understands that Users need to update or change User Personal Information from time to time. If the User needs to update or change Personal Information, the User can submit a written request via electronic mail (e-mail) to SmartNaira and provide SmartNaira with the relevant details. SmartNaira will help update and/or correct User Personal Information for Users, provided that such changes are not: i) endanger the security, physical health, or mental health of the Personal Data Subject and/or other persons; ii) has an impact on the disclosure of Personal Data belonging to other people; and/or; iii) contrary to the interests of national defense and security.

• 13.3 SmartNaira understands that Users need to update or change User Personal Information from time to time. If the User needs to update or change Personal Information, the User can submit a written request via electronic mail (e-mail) to SmartNaira and provide SmartNaira with the relevant details. SmartNaira will help update and/or correct User Personal Information for Users, provided that such changes are not: i) endanger the security, physical health, or mental health of the Personal Data Subject and/or other persons; ii) has an impact on the disclosure of Personal Data belonging to other people; and/or; iii) contrary to the interests of national defense and security.

14. Users’ Rights

You as a User of Our Product have rights to Your Personal Data, including but not limited to:

• 14.1 accepting the obligation from Us to maintain the confidentiality of Your Personal Data;

• 14.2 getting access to change or update their Personal Data to be accurate in the Product;

• 14.3 getting access to obtain historical Personal Data that has been provided to Us as long as it is still in accordance with the provisions of the applicable laws and regulations;

• 14.4 submitting an application for the destruction of Personal Data that We manage and store, unless otherwise determined by the provisions of the applicable laws and regulations;

• 14.5 receiving information regarding the purpose of use and disclosure of Your Personal Data by Us as mentioned in this Privacy Policy.

15. User Responsibility

• 15.1 The User agrees that User must only submit to us your Personal Information that is accurate and not misleading and you must keep it up to date as well as inform us of any changes (more information below). We reserve the right to request for documentation to verify the information provided by you. If you provide Personal Information of any third party to us, including but not limited to contact information of a third party for emergency contact purposes, you warrant to us that you have obtained the required consent from the relevant third party to share and transfer his/her Personal Information to us.

• 15.2 The user agrees to release and indemnify SmartNaira, affiliates, shareholders, directors, commissioners, employees, sub-contractors, providers, and or SmartNaira's agents for any requests, lawsuits, claims, losses, damages, including legal consultant fees, caused by violation of this Privacy Policy, Loan Agreement, Services and/or other agreements by User and SmartNaira.

16. Governing Law

• 16.1 This Privacy Policy is governed and interpreted in accordance with the provisions of the laws of the Republic of Nigeria.

• 16.2 If there is a dispute in the interpretation and/or exercise of the provisions of this Privacy Policy (“Dispute”), the User agrees to first resolve the Dispute by deliberation to reach a consensus within 30 (thirty) days from receipt of notification of the Dispute.

• 16.3 If the Dispute cannot be resolved by deliberation for consensus within 30 (thirty) days, the User agrees to resolve the Dispute at the Court where FLOODLIGHTS TECHNOLOGY is located.

17. Amendment

• 17.1 We reserve the right to amend this Privacy Policy at any time without advance notice unless required by law. All changes will be effective upon publication and shall be applicable to all users. Users are advised to check this Privacy Policy periodically.

• 17.2 Your continued usage of the Mobile Application, Website or Services after any change of this Privacy Policy shall be deemed as an acceptance by you of the changed Privacy Policy.

18. Withdrawal of Consent

You may express your objection to our continued use, collection and/or processing of your Personal Data for any lawful purpose and in the manner as stated at any time by contacting us at our email address. This will be your mechanism for terminating or permitting permissions previously granted to us. Please note that if you raise your objection to the processing of certain Personal Data, depending on the nature and subject of your objection, the same may impact the timeline of your application and/or our analysis of your credit worthiness. Our legal rights and remedies are expressly protected by law in such events.

19. Contact Us

If you have questions, comments and requests or other matters related to the Product, you can contact SmartNaira's officers via:

E-mail : service@smartnaira.app
Phone : +234-8038020029