1. Introduction
Elite Creed Capital ("we," "our," or "the Company") is committed to protecting your personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR). This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our vehicle-backed lending platform.
2. Data We Collect
We collect the following categories of personal data:
- Identity Data: Full name, date of birth, National Identification Number (NIN), Bank Verification Number (BVN), government-issued ID.
- Contact Data: Email address, phone number, residential address.
- Financial Data: Bank account details, employer information, monthly income, loan history.
- Vehicle Data: Vehicle make, model, year, registration number, chassis/VIN number, vehicle photographs.
- Transaction Data: Loan amounts, payment history, deposit records, commission payments.
- Technical Data: IP address, browser type, device information, session data.
3. Purpose of Processing
Your personal data is processed for the following purposes:
- Loan application processing and credit assessment
- Identity verification and KYC (Know Your Customer) compliance
- Vehicle valuation and collateral assessment
- Payment processing and loan servicing
- Fraud prevention and anti-money laundering (AML) compliance
- Regulatory reporting (CBN, FIRS, SCUML, NFIU, FCCPC)
- Communication regarding your account and transactions
- Marketing attribution and analytics (with your consent)
4. Legal Basis for Processing
We process your data based on:
- Consent: You provide explicit consent at registration and loan application.
- Contract: Processing is necessary for loan agreements and services.
- Legal Obligation: Compliance with CBN regulations, NDPA, FIRS, AML laws.
- Legitimate Interest: Fraud prevention and business operations.
5. Data Security
We implement appropriate technical and organizational measures to protect your data:
- 256-bit SSL encryption for data in transit
- AES-256 encryption for sensitive documents at rest
- Role-based access controls with audit logging
- Regular security assessments and monitoring
- Secure session management with automatic timeout
6. Data Retention
We retain your personal data for:
- Active loan duration plus 7 years (regulatory requirement)
- KYC/AML records: minimum 5 years after relationship ends
- Transaction records: as required by FIRS for tax purposes
7. Your Rights
Under the NDPA, you have the right to:
- Access your personal data held by us
- Rectify inaccurate or incomplete data
- Request deletion of your data (subject to legal retention requirements)
- Withdraw consent at any time
- Object to processing based on legitimate interest
- Data portability
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC)
8. Third-Party Sharing
We may share your data with:
- Regulatory bodies (CBN, NDPC, FIRS, SCUML, NFIU, EFCC) as required by law
- Investors funding your loan (limited to loan and collateral details)
- Payment processors for transaction processing
- Vehicle valuation services for collateral assessment
We do not sell your personal data to third parties.
9. Contact Us
For privacy-related inquiries or to exercise your data rights:
Data Protection Officer
Elite Creed Capital
Ryanan Shopping Centre, Opposite Labour Congress, NTA Road, Asaba, Delta State
Email: privacy@elitecreed.com