KoboGo

KOBOGO NIGERIA LIMITED

Privacy Policy

Introduction

KoboGo Nigeria Limited (“KoboGo”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you of how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
10. [GLOSSARY]
IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how KoboGo collects and processes your personal data through your use of this website, including any data you may provide through this website when you use any of our services, enter into a loan agreement with us, send us an enquiry or complaint, or when you sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware ]of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

KoboGo is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

  • Full name of DPO: NDIMELE OBINNA EMMANUEL
  • Email address: kobogo.nigeria@gmail.com
  • Postal address: 48, Awolowo Road, Ikoyi, Lagos, Nigeria
  • Telephone number: +234 806 698 8178

Changes to the Privacy Policy

We keep our privacy policy under regular review. This version was last updated on March 23, 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data means any information relating to an identified or identifiable natural person. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, photograph/photo ID, National Identification Number (NIN), gender, and employer details.
  2. Contact Data includes residential address, email address and telephone numbers.
  3. Financial Data includes bank account details, bank verification number (BVN), card details, and income details.
  4. Transaction Data includes details about payments to and from you.
  5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  6. Profile Data includes your username and password, preferences, feedback and survey responses.
  7. Usage Data includes information about how you use our website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

In order to provide you with safe, personal and seamless access to our services, we may collect, and process information stored on your device, including contact lists, call logs, SMS logs, contact lists from other social media accounts, photos, videos or other digital content. This information will be accessed only with your express consent to your device’s permission on the APP. You may at any time allow or disallow access to the information stored on your device by changing your device’s settings. In addition, we collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a loan). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling out forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • a. apply for our products or services e.g., a loan;
    • b. create an account on our website;
    • c. subscribe to our newsletters;
    • d. request marketing to be sent to you;
    • e. enter a competition, promotion or survey; or
    • f. give us feedback or contact us.
  2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  3. Third parties or publicly available sources. We may also receive and use personal data about you from various third parties e.g., analytics providers such as Google and public sources.
HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

  1. Where we need to perform the contract we are about to enter into or have entered into with you.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal obligation.
  4. When you give us consent.

We will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Lawful basis for processing including basis of legitimate interest
To provide products and services which you have requested, and to conduct business with you (for example, to register you as a new customer, to process your application, to manage your account, to tell you about important changes to our services, to process and to respond to your enquiries, complaints and issues) and to keep updated and bring together and improve records. Performance of a contract with you
To provide an initial quotation where you have applied for a loan.

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (ensuring that customers have a clear understanding of the product they have applied for)

For security, credit, identification and verification purposes.

(a) Comply with a legal obligation (e.g., compliance with our Anti-Money Laundering and Know Your Customer obligations).

(b) Legitimate interests (we consider that it is in our legitimate interest to ensure security and to prevent fraudulent activity in the use of our services).

To detect, investigate, prevent and prosecute criminal activity and to meet our regulatory, legal and compliance obligations (including performing regulatory and prudential compliance checks on an ongoing basis, account and transaction monitoring, checks for sanctions and politically-exposed persons, and transaction and tax reporting. Also making disclosures to, cooperating with, and complying with requests from public authorities, regulators, courts of law, tax authorities, governmental bodies or law enforcement agencies, and investigating and preventing fraud, terrorism and other crime).

(a) Comply with a legal obligation

(b) Legitimate interests (ensuring effective compliance in all relevant jurisdictions, protecting our customers, maintaining a good relationship with law enforcement, regulators and other relevant authorities. We also consider that we have a legitimate interest in protecting our legal rights.)

To assess lending and insurance risks. Legitimate interests (we consider that we have a Legitimate Interest in ensuring that the risk to which we are exposed remains within our risk tolerance).
To collect money that you owe us, and to exercise our rights set out in agreements.

(a) Performance of a contract with you

(b) Legitimate interests (we consider that we have a legitimate interest in collecting money owed to us, to ensure our ongoing financial stability.

To improve customer service, and to decide if a product or service is suitable for your needs. Legitimate interests (we consider that we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively. We also consider that we have a legitimate interest in ensuring that we provide our customers with appropriate products and services, to ensure both appropriate risk management and good client relationship management.
To provide you with the appropriate level of service, to accommodate your specific individual needs and treat you fairly based on any vulnerability you may have, whether you have told us or we believe necessary to record, to improve customer service and ensure equality of treatment, protect vulnerable customers or safeguard your economic wellbeing.

(a) Consent

(b) Public Interest

(c) Vital Interest

(d) Legitimate interests (we consider that we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively).

To carry out operational and administrative functions (e.g. to maintain our own accounts and records, operate information technology systems, carry out billing-related and payments administration, maintain stocks and shares registers).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or we have provided products or services to you and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://static.kobogo.ng/cookies-policy.html

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with third parties for the purposes set out in the table [Purposes for which we will use your personal data] above.

[Specific third parties such as [SPECIFIC THIRD PARTIES]]

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

[IF NO TRANSFERS OUT OF NIGERIA OCCUR:] We do not transfer your personal data outside of Nigeria].

OR

IF TRANSFERS OUT OF NIGERIA OCCUR:] We share your personal data within the [COMPANY] Group. This will involve transferring your data outside Nigeria].

[IF BINDING CORPORATE RULES ARE USED:] [We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see [ ].]

[Many of our external third parties are based outside Nigeria so their processing of your personal data will involve a transfer of data outside Nigeria.]

Whenever we transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in Nigeria which give personal data the same protection it has in Nigeria.

[OTHER].

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Nigeria.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation concerning our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In certain circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have rights under data protection laws in relation to your personal data. You may:

  1. Request access to your personal data
  2. Request correction of your personal data
  3. Request the erasure of your personal data
  4. Object to processing of your personal data
  5. Request restriction of processing your personal data
  6. Request transfer of your personal data
  7. Right to withdraw consent
  8. Right to lodge a complaint with the relevant authority

If you wish to exercise any of the rights set out above, except the right to lodge a complaint with the relevant authority, please contact our DPO.

No fee usually required

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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

Lawful Processing

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Internal Third Parties

Our Affiliated Companies acting as joint controllers or processors who provide IT and system administration services and undertake leadership reporting.

External Third Parties

  1. Partners and service providers acting as processors who provide IT and system administration services.
  2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  3. Regulators and other authorities based in Nigeria, that require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to lodge a complaint with the relevant authority if you have any complaint about how we process your personal data.