What information do we collect?

Information you give us on Fludicial We collect and use any information you supply when you interact with any of our touch points. When you open an account with us, you share details like your name, BVN, ID, address and a picture. By using our card or the app to transact, you also share details of your transactions with us. Additionally, we may request explicit permission to see other information like your address book, location, photos and data from your camera.

Details you give when you sign up for a Fludicial account, like your BVN, name, date of birth, gender, phone number, residential address, and email address. Your profile picture. We collect a video of your face during a liveness check done to confirm that you're the one upgrading your Fludicial account. We then share this video with a third-party service to facilitate our liveness check. You may choose not to upload a video of your face on the app, however, this will limit what you can do with your Fludicial account. We will not share the video of your face that we collect during a liveness check with advertisers or anyone else other than the third-party service that facilitates the liveness check process. If at any time you choose to withdraw your consent for us to use this video for your liveness check, we will delete it. Also, if you choose to delete your Fludicial account, we will delete any data we have previously collected from you including the video of your face uploaded during the liveness check. Information you give us through the in-app chat so we can help you. Information you give us when you contact us If you contact via other means than the in-app chat, we collect the following information so we can answer your questions or take action. The phone number you’re calling from and information you give us during the call The email address you use and the contents of your email (and any attachments). Public details from your social media profile (like Facebook, Instagram or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us. Information we collect when you use Fludicial The mobile network and operating system you use, Your IP address and device ID Your phone contacts so you can make airtime purchases or pay contacts on Fludicial Information we get from third parties As part of our KYC (Know Your Customer) process, we run checks on the ID information you supply during signup. Also, we run further checks with the credit bureaus to check if we can offer you an overdraft. How do we use your information? The Nigerian Data Protection Regulation says we need to have a lawful basis for using your personal information. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent. Contractual Obligation We collect certain data from you to fulfil the contract we have with you, or to enter into a contract with you. We use this data to: Give you the services we agreed to in line with our terms and conditions. Send you messages about your account and other services you use if you get in touch, or we need to tell you about something. Exercise our rights under contracts we’ve entered into with you, like managing, collecting and recovering money you owe us. Investigate and resolve complaints and other issues. Legal Duty We have to ensure we aren’t breaking any laws by banking you by preventing illegal activities like money laundering and fraud. To do this, we need your data to Confirm your identity when you sign up or get in touch. Prevent illegal activities like money laundering, tax evasion and fraud. Keep records of information we hold about you in line with legal requirements. Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties). Legal Duty We have to ensure we aren’t breaking any laws by banking you by preventing illegal activities like money laundering and fraud. To do this, we need your data to Confirm your identity when you sign up or get in touch. Prevent illegal activities like money laundering, tax evasion and fraud. Keep records of information we hold about you in line with legal requirements. Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties). Legitimate Interest In some instances, we need to use the data you supply us for our legitimate interests. This means we’re using your data in a way that you might expect us to, for a reason which is in your interest and doesn't override your privacy, interests or fundamental rights and freedoms. Consent For certain information, we’ll ask for your consent. We’ll ask for your consent to: Market and communicate our products and services. You can always unsubscribe from receiving these if you want to Help protect you against fraud by tracking the location of your phone if you’ve Help protect you against fraud by tracking the location of your phone if you’ve authorised it View your contact list for airtime purchases. Who do we share your information with? In some instances, we will share the information provided with some third parties that we do business with, like card producers and credit agencies, or with law enforcement agencies when required. How long do we keep your data? We keep your information as long as you are a Fludicial customer and for any additional period as required under applicable law or regulations. These retention requirements supersede any right to erasure requests under applicable data protection laws. We cannot therefore erase your data in relation to your Fludicial Account until after this time period, however we can assure you that your data will be held safely and securely whilst under our supervision. When do we delete your data? We are basically storing and processing your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires us to store it. If you choose to delete your Fludicial account, we will delete any data you have previously given us, including the video of your face uploaded during the liveness check. What are your rights? You have the right to access and request the information that we have for you in our records. You may also ask us to delete our record of you, restrict the way in which we use your personal information, request a copy of the information we hold about you, ask that we update the personal information we hold about you or correct such personal information which you think is incorrect or incomplete, and we will grant this request as long as we’re legally allowed to. You also have the right to object to us using your information for our marketing purposes or any additional services we may be offering you. Lastly, you may also withdraw any consent you’ve previously given us.