This notice explains how we handle your personal data and our attitude towards data protection.
The Information We Collect
- We collect and process information which:You give to us when you register with us, such as your name and contact details.
- We obtain from Credit Reference Agencies on your behalf.
- We collect about you based on your use of our website.
- We receive from other sources, such as third parties who give us information about you.
- We may collect and process the following data about you.
Information You Give Us
- You may give us information about you when you use our services or by communicating with us. This includes information you provide when you participate in discussion boards, answer specific questions on our website, provide us with feedback, participate in surveys, and when you report a problem. The information you give us may include:Title
- Email address.
- Date of birth
- Phone number
- Monthly expenditure
- Residential details
- Employment details
- Address history
- Property value
- Driving license details
- Lifestyle information
Information We Collect from Credit Reference Agencies on your behalf
If you register to use our services, we will obtain your credit score and credit report from one or more Credit Rating Bureau on your behalf.
Information We Collect from Our Partners on Your behalf
Each time you visit our website we may automatically collect the following information:
- Technical Information: including the Internet protocol (IP) address, your login information, browser type and version, time zone setting, operating system and platform;
- Information about your visit: including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information We receive from Other Sources
We may receive information about you if you use our website. We are also working closely with third parties (including, for example, business partners, service providers, analytics providers, search information providers, social media) and may receive information from them, such as your credit report information, whether or not you have taken out a product with them, what other products you may have used, and other such details. How We use the Information
We use information we hold about you to provide our services to you, improve those services, administer your account, to fulfil our legal obligation, respond to your enquiries, customer support, manage our relationship with you, and communicate with you and to use information on an anonymous basis for research and analytical purposes. Information you give to Us or We collect from Credit Reporting Bureaus, Partners or Other Third Parties on Your behalf as part of Our Services
- Administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message, push notification or other electronic means;
- Verify your identity as part of our identity authentication process;
- Provide you with information, products and services;
- Where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you;
- Notify you about changes to our services;
- Ensure that content from our website is presented in the most effective manner for you and your device;
- Aggregate it on an anonymous basis with other data for data analytical and reporting purposes; and
- Undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances or to enhance our services.
Information We Collect about You based on Your use of Our Website
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve the services we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- As part of our efforts to keep our website safe and secure and to prevent fraud;
- To make recommendations about products or services that may be of interest. Information We receive from Other Sources
We may combine this information with information you give to us and use this information and the combined information for the purposes set out above. Recording Telephone Calls and Other Communications
We will use telephone recordings or transcripts of communications to check your instructions to us, analyse, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us.
What We will never Do
Rest assured, we will never sell your information to third parties.
Who We may Share Your Data with
We may share your data with other third parties, such as our service providers, Credit Rating
Bureaus, and Anti-Graft Agencies and Partners. We may need to disclose your data to others to ensure the smooth provision to you of the products, services and information you request. Your data may be disclosed to the other entities as described below. These third parties act on our instructions and are processors of your information. The personal information we have collected from you will be shared with Background Check agencies who
will use it to verify your identity. We will share your data due to our legal obligation to ensure we meet know your customer (KYC) and anti-money laundering obligations under extant laws.
- We may share your information with the following sub-processors:Google
- Nigerian Interbank Settlement System(NIBSS)
Selected Third Parties
- We may also share your information with selected third parties including:Credit Rating Bureaus, to obtain your credit score and credit report on your behalf and to provide our services to you;
- Background Check agencies, to verify identity;
- Anti-graft agencies or other regulators to comply with our legal obligations;
- Product providers, such as our business partners who offer you credit cards, loans,
car finance, mortgages, insurance, pensions, investments and other related products, to:
- assess if you are an existing customer and for Background Check purpose;
- conduct analysis to provide you with better products and services in the future, and for segmentation purposes;
- pre-fill an application form with the product provider;
- assess your probability of being accepted for a product
- Analytics and search engine providers that assist us in the improvement and optimisation of our service
- If 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 (or the buyer or seller’s advisers)
- If we or part or all of our assets are acquired by a third party, in which case personal data held by us about our 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 obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of Pocketfuel, our customers, or others.
This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The Product provider does not have permission to use this data for any other purpose including marketing.
Credit Rating Bureaus
If you register to use our services we will obtain on your behalf, in accordance with our Terms, copies of your credit report and credit score from designated Credit Rating Bureau. In order to provide these services to you, we will share your information with such Credit Rating Bureaus. The information which we provide to the CRB may be supplied by them to other organisations such as Background Check Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRB may also use the data to undertake statistical analysis. If you choose to apply for a product, the lender will undertake a full credit check and provide you with further privacy information for that product.
What is the Legal Basis for Us using this Information
We make appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases upon which we collect and use your personal data, you can contact our Data Protection Officer. Our lawful bases may include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (such as delivering our core services to you) and, legal obligation, and our own legitimate interests.
We will always seek your consent to process certain types of information where we are legally required to do so. You have the right to withdraw or decline your consent at any time.
Performance of Contract
Processing your data is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.
Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. These legitimate interests are:
- Delivering, developing and improving our website;
- Enabling us to enhance, customise or modify our services and communication;
- Determining whether marketing campaigns are effective;
- Enhancing data security.
Direct Marketing and how You can Change Your Preference
We offer you the opportunity to receive marketing information from us. You can opt out easily of receiving marketing from us at any time. We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods, such as push notifications to your devices. You may receive the following types of communications from us:
- Product recommendations * - we’ll get in touch with personalised, timely product recommendations that can help you improve your financial situation. We will only ever send these if you explicitly consent to receiving them and you can unsubscribe whenever you like.
- Content communications - we’ll send you content such as tips, research, features and news, coaching programmes on how to keep on top of your money and other related content. You can unsubscribe from these at any time and we will never spam your inbox.
- Core communications - we will send you your credit report every month, alerts whenever there is a change to your credit report, security alerts pertaining to your Pocketfuel account, significant changes which may impact our service and other such related content. These communications are an intrinsic part of owning a Pocketfuel account and cannot be opted-out of.
How We protect Your Information
We take the security of your data very seriously and use strict procedures to protect it. Whenever we transfer personal data Nigeria, we ensure that appropriate safeguards are in place to protect the data. All information you provide to us is stored on our secure servers. We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website; 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, loss or damage. Where possible, we try to only process your information within Nigeria. If we or our service providers transfer personal data outside Nigeria, we always require that appropriate safeguards are in place to protect the information when it is processed.
How long We keep Your Information for
While your account remains active, we keep your information for no longer than is necessary depending on the purpose for which we are using it. We will keep your credit information for an initial period not less than six (6) years from the date such information is provide, and archived for a period of ten (10) years in compliance with the provision of Section 5 of the Credit Reporting Act, 2017. How long we keep your information will depend on the purpose for which we use it. While you are a customer of ours, we will only retain your information for as long as is necessary for those purposes. After termination of your account, we may continue to use anonymised data (which does not identify individual users) which is aggregated with anonymised data of other users. We use this aggregated anonymised data for data analysis and research purposes, for example to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us as well as your name, date of birth and latest address for Background Check purposes and for the exercise or defence of a legal claim.
Links to and from Third Party Websites
Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these policies.
Automated Decision Making
We use an automated decision making system to make automated decisions based on personal information we have about you. This helps us to make sure our decisions are quick and fair, based on what we know. We use automated processing for the following purposes:
- Identity verification - We use an automated decision making system to verify the details you provide against those held by third party providers. If you do not pass the check using the automated system, we cannot provide our services to you without being able to verify your identity.
- Tailored products and services - We may use your information to predict the probability that you may be accepted for a product, or to determine the best order or manner in which to display products to you.
- Tailored communications - We want to make sure we’re only sending you emails that are relevant to you, and so we will use your personal information to determine which content you may be more interested in receiving. You’ve the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about automated decision making, please contact us via email@example.com
You can exercise specific rights with regards to the data that we hold about you. You will be able to:
- Correct your data - you will usually be able to amend any information that we hold about you that is inaccurate or incomplete through the settings in your account;
- Request access to your data - you can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with data protection law;
- Erase your data - you can ask us to fully or partially delete your personal data where there is no compelling reason for us to keep using it, although we may not be able to continue to provide our services. We may keep your email address to make sure the restriction is respected in future. We also have the right to continue using your information if such usage is necessary for compliance with our legal obligations;
- Download your data or send it to another controller - you can obtain a copy of the data you provided us in a machine-readable format. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party;
- Restrict the use of your data - You have the right to 'block' or suppress further use of your information in certain circumstances (for example, where you think the information we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your information, but may not use it further;
- Right to withdraw consent - If you have given your consent for us to use your information, you have the right to withdraw your consent at any time. This can be done by contacting our Data Protection Officer;
- Right to lodge complaint with the Regulator: - If you are not satisfied with our response to any complaints you raise with us or you believe our processing of your information does not comply with the data protection law, we suggest you contact our Data Protection Officer. However, you can make a complaint to the Central Bank of Nigeria or the National Information Technology Development Agency.
For the exercise of any of your rights, you can also contact us at firstname.lastname@example.org
All access requests, questions, comments, complaints and other requests regarding the cookies policy should be sent to email@example.com We may request additional details from you regarding your complaints and keep records of your requests and resolution.