MFN are committed to protecting and respecting your privacy.
This privacy policy (Policy) and any additional terms of use applies to your use of:
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It is in compliance with the Constitution of the Federal Republic of Nigeria 1999, Nigerian Data Protection Act 2023 (the “Act”), and Nigeria Data Protection Regulation 2019 (the “Regulations”)
We may collect and process the following data about you.
1) Information you give us about you (Submitted information):
This may include information:
This information may include your name, gender, occupation, Bank Verification Number, National Identification Number, address, e-mail address and phone number, the Device's phone number, SIM card details, age, username, password and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description and photograph (“Personal Data”).
2) Information we collect about you and your device.
When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
Each time you visit one of our Sites or use one of our Apps, we may automatically collect the following information:
3) Location information.
We may also use GPS technology OR other location services to determine your current location. You can withdraw your consent to our collection, processing or use of this information at any time by logging out and uninstalling the App from your Device.
4) Information we receive from other sources (Third Party Information).
Due to the nature of the Services which we provide, we are required to work with a number of third parties (including banks, identification verification companies, payment service providers, credit reference agencies, debt recovery companies, financial services providers and mobile network providers) and we may receive information about you from them.
5) Unique application numbers.
When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site, or Service Sites. This helps us to provide you with a good experience when you use the App or browse any of the Service Sites and also allows us to improve the App and Our Service Sites.
We access this information through your mobile device operating system when you give consent to your device’s permissions on our App.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined. Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied for a loan on any given day).
You hereby consent to the processing of your data by us. We shall obtain your consent for and to individual matters, where any document deals with different matters.
We can process your personal data in the absence of consent where:
If we intend to use your data for a purpose which is different from the purpose for which your data was obtained, we will seek your consent prior to the use of your data for that other purpose.
In the event of any arrangement whereby MFN is merged or combined with another entity (ies), sells or transfers all, or a portion of, its business or assets (including in the event of an internal or external restructuring, reorganization, dissolution or liquidation) to third parties, you hereby consent that your personal data held with MFN can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by MFN prior to such arrangement. MFN shall at all times ensure that you are notified when your personal data is intended to be transferred to third parties in the circumstances outlined in this clause.
No Consent shall be sought, given or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.
You reserve the right to request the modification or amendment of your personal data in our possession.
In all cases of access or modification/amendment of personal information, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed or modified/amended.
You have certain rights in relation to the way we handle your Personal Data. These include the following rights:
When we process your personal data, we are guided by the following principles, which require personal data to be:
We will only share personal information with other companies or individuals in the following limited circumstances:
MFN is at all times, responsible for the security and appropriate use of that data as long as it remains with MFN.
You are required to familiarize yourself with this policy and to ensure that the information you provide to us is complete, accurate and up to date.
Subject to the provisions of paragraph D(a) above, we may disclose some or all of the data we collect from you when you download or use the App.
We may disclose your personal information to third party partners such as banks, payment companies, asset management firms, identity verification companies, credit reference bureaus, debt recovery companies, or any other person (entity) that provides any form of service or information to us for the provision of the Service.
We may disclose your personal information to any member of our group, which means our subsidiaries, affiliates, our holding company and its subsidiaries.
We may disclose your personal information to third parties:
You consent to us disclosing or providing your personal information under any of the circumstances set out in this Paragraph.
The data that we collect from you may be transferred to, and/or stored at, a destination outside your country of origin or residence (as applicable).
By providing your consent to this policy, you also authorise us to transfer your Personal Data provided to us out of Nigeria to other entities within the MFN Group or third parties with the understanding that the data may be used for the purpose stated in our contract or terms of engagement with such entities. We are required to let you know that your Personal Data may be transferred outside Nigeria to the United States of America, Kenya, India, or any other country where a MFN entity is incorporated. (“Foreign Recipients”). By continuing to use our Services or Service Sites, you explicitly consent to the transfer of your Data to any of the Foreign Recipients mentioned above.
We assure you that we will protect your Personal Data in our possession and we confirm that the security measures in place both in Nigeria and the Foreign Recipients are more than adequate to protect your Personal Data. We confirm that we take appropriate physical, management, and technical measures, such as the establishment of the access control system and monitoring system, encryption, anonymisation or pseudonymisation, employee training, to protect your Personal Data against unauthorized access, use, disclosure, modification, damage, loss, or other forms of illegal processing. Our information security policies and procedures are designed in strict accordance with international standards, and are reviewed and updated regularly. We implement and maintain appropriate safeguards to protect Personal Data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to their personal data. If we collect your Personal Data, you can contact us for a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances.
By submitting your personal data, you also agree to the collection, transfer, storing or processing of your personal data in the manner set out above.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
MFN's use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
We implement and maintain appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to their personal data.
Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting the confidentiality (i.e. that only those who need to know and are authorized to use personal data have access to it), integrity and availability of the personal data. We regularly evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal data.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot guarantee absolute security. MFN, therefore, accepts no liability for any damage or loss, however caused, in connection with transmission over the internet or electronic storage.
Our Service Sites may contain links to other websites owned and operated by third parties. These links are provided for your information and convenience only and are not an endorsement by MFN of the content of such linked websites or third parties. The information that we collect from you will become available to these websites if you click the link to the websites. These linked websites are neither under our control nor our responsibility. MFN, therefore, makes no warranties or representations, express or implied about the safety of such linked websites, the proprietors or operators of those websites, and the suitability or quality of information contained on them. This Privacy Policy does not apply to these websites, thus, if you decide to access these linked third party websites and/or make use of the information contained on them, you do so entirely at your own risk. MFN accepts no liability for any damage or loss, however caused, in connection with accessing, the use of or reliance on any information, material, products or services contained on or accessed through any such linked website. We advise that you contact those websites directly for information on their privacy policy, security, data collection and distribution policies.
We will use your data for the purposes of compiling statistics relating to our user base or loan portfolio and any other product or service we provide and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.
Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at [email protected]
You have the right to know the nature of your personal data which we have in our possession. We shall attend to your request to access such information and shall provide you with a copy of your personal data which we hold at the time such application is made. You reserve the right to request the modification or amendment of your personal data in our possession. In all cases of access or modification / amendment of personal information, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed or modified / amended.
When we process your personal data, we are guided by the following principles, which require personal data to be:
We have put in place procedures to deal with any suspected personal data breach and will notify you of any personal data breach and let you know the steps we have taken to remedy the breach and the security measures we have applied to render your personal data unintelligible.
All suspected breach of personal data will be remedied within 1 (one) month from the date of the report of the breach.
If you know or suspect that a personal data breach has occurred, you should immediately contact the MFN team at [email protected].
MFN will not be responsible for any personal data breach which occurs as a result of:
MFN shall retain and use your Data only as long as is necessary to implement, administer and manage your request and contract with MFN, or as required to comply with legal or regulatory obligations, including under tax and security laws. We may retain your Data for a minimum of 6 years (or such longer period as may be necessary) even after we have received a request for deletion from you in order to comply with our regulatory obligations. We will retain your Data if there is an outstanding obligation or duty from you.
Notwithstanding, a request for erasure will automatically be denied in whole or in part, where it would adversely affect a constitutionally guaranteed right, contradict a legal obligation, act against the public interest in the area of public health, act against the public interest in the area of scientific or historical research, or prohibit the establishment of a legal defense or exercise of other legal claims by MFN or any legitimate third party. Where a request for erasure is denied, MFN will provide to you the specific reason for denying the request as soon as possible but no later than one month after receiving the request for erasure.
Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Service Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. In any event, by continuing to use the App or any Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]