Cloverleaf Microfinance Bank – Privacy Policy

This privacy policy (Policy) together with our Terms of Use and Loan Account Agreement as set out and any additional terms of use applies to your use of:

1. Cloverleaf mobile application software (App) available on our site OR hosted on the Google Play Store (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
2. Any of the services accessible through the App (Services) or those available on the App Site or other sites of ours or other third-party Sites (Service Sites).

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.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading the App, you confirm that you have read, understood and accept the terms of this Policy set out hereunder. You also consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy.

A. Information we may collect from you

We may collect and process the following data about you.

i. Information you give us about you (Submitted information):

This may include information:

• provided by filling in forms when visiting our sites or on our App;
• provided by corresponding with us (for example, by e-mail or chat);
• provided by downloading or signing up on the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App’s social media functions, entering a competition, promotion or survey, and reporting a problem with the App, our Services, our App Site or any of Our Service Sites.

This information may include your name, address, e-mail address and phone number, the Device’s phone number, 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.

ii. Information we collect about you and your device.

Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:

• technical information, including the type of mobile device you use, unique device identifiers (for example, your Device’s IMEI or serial number), information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information);
• information stored on your Device, including contact lists, call logs, SMS logs, social media accounts, other financial applications, photos, videos or other digital content (Content Information);
• data from your use of any other third-party application on the Device or the Service Sites; and
• details of your use of any of our Apps or your visits to any of Our Service Sites; including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information).

iii. Location information.

We 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.

iv. 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 credit reference agencies and mobile network providers) and we may receive information about you from them.

v. 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.

B. Tracking and cookies

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.

C. Uses made of the information

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.

Information collected by us shall be used for the purpose of determining whether or not to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan.

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).

D. Disclosure of your information

We may disclose some or all of the data we collect from you when you download or use the App to credit reference bureaus.

E. App permissions

To assess your eligibility, determine the best offer for you and disburse your loan faster, we would need the following permissions from you.

●     SMS: We collect all your SMS data but only monitor your messages related to financial transactions. To be specific, we will monitor the name of the sender, the description and the amount of transaction to perform credit risk assessment. This enables faster and quicker loan disbursal. No personal SMS data is monitored, read, stored or shared.we will upload SMS data to Cloverleaf server with high level protection and will not be shared with any third party.

●     Contact: We gather your phonebook contacts which includes their phone contact names, phone numbers, contact added date to augment your credit profile, additionally, this can allow you to choose your references in the loan application or share our app invitation to your friends easily. We will upload Contact data to the Cloverleaf server with high level protection.

●     Location: Collect and monitor information about the location of your device for customer risk assessment and scoring.We will upload location data to the Cloverleaf server with high level protection.

●     Media: Collect and monitor media information such as images and documents. We will upload image and documents data to our servers and ensure it is secure with high level protection.

●     Device: Collect and monitor specific information about your device including your device name, model, region and language settings, device identification code, device hardware and software information, status, usage habits, unique device identifiers like IMEI and serial number to uniquely identify the device and ensure that unauthorized devices are not to act on your behalf to prevent frauds.We will upload collected data to the Cloverleaf server with high level protection.

F. Data storage

Regarding all the collected information, we will store it with high level protection in accordance with the data protection laws in Nigeria

How do we use your data

We collect certain data to be able to provide the Service to you. We also collect data for use in verifying your identity and creating credit scoring models to determine what Loans can be offered to you. We also use this data for purposes of collections and credit reporting.

1. The data we collect

When you register for the Service, we will collect your bank number and telephone number and may also collect your name, age, email address or other contact information. With this information, we cross-check your identity with third parties including the person you have provided as your emergency contact. We will also collect data from your device for our credit scoring system. This includes information relating to your device, such as device maker and model, operating system, installed software applications, and the unique user identifier. We also collect your email and phone-book contacts and information related to device activity such as SMS logs and GPS location information. To supplement this information, we also collect data from third parties such as credit bureaus and other financial institutions. By registering for the Service, you authorize the collection and processing of the foregoing data.

We will ensure that your data is protected to a strict standard.

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:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if Cloverleaf or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or
• in order to: enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

1. Where we store your personal data

The data that we collect from you may be transferred to and stored at a destination outside your country of origin or residence (as applicable) where the data protection laws may differ from those in your jurisdiction. It may also be processed by staff operating outside your country of origin or residence (as applicable), who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests on the Service Sites. By submitting your personal data, you agree to the collection, transfer, storing or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this Policy.

1. Security of Data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Notwithstanding the undertaking above, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, using global best practices, 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 unauthorised access.

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. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences.

If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. You are reminded to log off from your account and close the browser when finished while using a shared computer.

1. Your Privacy Rights

You have the following privacy rights:

• Right to Rectification: You can modify or change your name, email, password, and mobile login PIN through your profile.
• Right of Access, Erasure, and Restrict Processing: You can request access or erasure of your personal information, as well as request restriction on further processing of your data/personal information by contacting us at info@cloverleafmfbank.com.ng. Please allow up to 30 days for requests to be processed. We reserve the right to charge a reasonable fee to process excessive or repeated requests.
• Right to Withdraw Consent: You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send, or by adjusting your Marketing Preferences in your profile. You can also have choices with respect to cookies, as described above.
  By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Service may not work properly in your case.
• Right to lodge a complaint with a supervisory authority: Should you feel your data privacy rights are not being adequately protected by us, you have the right to lodge a formal complaint with the appropriate supervisory authority.

1. Legal Age

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child or children have provided us with personal data, please contact us at info@cloverleafmfbank.com.ng. If we become aware that we have collected personal data from children without verification of parental consent, we shall take steps to remove that information from our servers.

1. Links to Other Sites

The App may provide hypertext links to other sites operated by other people. Using such a link means you are leaving the App. We take no responsibility for, and gives no warranties, endorsements, guarantees or representations in respect of, linked sites. We are not responsible for the privacy practices, nor do we accept any liability in connection with the content of, such websites or applications, which will in some cases have their own privacy policies tailored for the particular business practices in which they operate. Any concerns regarding any external link should be directed to its website or app administrator.

1. Changes to the Policy

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.

1. Contact Us

Contact us by sending an e-mail to info@cloverleafmfbank.com.ng if you have any questions about this Policy.