Swiftnaira

Thank you for using the Swiftnaira application. In order to legally carry out Swiftnaira operations in Nigeria,
LINWOOD TECH SERVICES LTD and FINNEW FINTECH LIMITED have entered into a cooperation agreement,
establishing an "Authorized Operation" relationship. Under this cooperation, this application is fully operated and
owned by LINWOOD TECH SERVICES LTD, which provides compliance services under the financial license
provided by Finnew Fintech Limited. We strictly adhere to financial regulatory requirements, with all fund
transactions and risk control measures directly implemented by LINWOOD TECH SERVICES LTD to ensure the
security of your funds and legal rights. The following obtained information will be encrypted, uploaded, and stored
within the LINWOOD TECH SERVICES LTD, and will not be shared with unauthorized third parties.

This Privacy Policy applies specifically to the Swiftnaira app and aims to fully explain our commitment and procedures for protecting user personal data. We deeply understand the importance of personal information security in safeguarding user rights, and as such, this policy systematically outlines the following core elements: the scope of data collection (including identity verification, financial qualifications, credit assessments, and other necessary information), the purposes of data collection (such as risk assessment, service optimization, and compliance requirements), data processing standards (bank-grade encryption for storage and transmission), third-party sharing criteria (strictly limited to regulatory permissions), data lifecycle management (including storage duration and deletion mechanisms), and measures to protect minors (strict prohibition of use by users under 18 years old). Contact information for the data protection officer and complaint channels are detailed at the end of this policy. By registering or continuing to use this platform's services, you acknowledge that you have read, understood, and unconditionally accept all the terms of this policy. This agreement is legally binding, and you commit to providing accurate, truthful, and complete information. We reserve the right to update this policy in a timely manner based on business developments and legal changes, with major changes being communicated to users through platform announcements or other means.

Information We Collect

When you register for our app or use our services, we collect the following information:

1. Identification-related information - To complete identity verification, we require basic information such as your full name, valid phone number, date of birth, email address, and device advertising ID. This information is strictly used to establish your exclusive account profile, conduct real-name authentication, and contact you in special circumstances (e.g., account issues). We solemnly promise not to contact you except in these special cases or disclose any loan-related information to emergency contacts in your address book. It is important to note that your phone number is used only during registration and login. All identity information obtained will be securely encrypted via HTTPS and sent to our server at https://api.swiftnaira.com.

2. Financial-related information - During credit evaluation, we are required to verify your bank account information, including but not limited to bank verification number (BVN) and other key financial identifiers as mandated by regulations. This data is crucial for risk assessment purposes but will not be used for any other unrelated services. All financial information obtained will be securely encrypted via HTTPS and sent to our server at https://api.swiftnaira.com.

3. Credit-related information - To build an accurate credit evaluation model, the system analyzes technical parameters such as device model, operating system version, and a list of installed applications. Additionally, with your explicit consent, we may access contact details from your selected address book and device location records (only during service use). All data collection follows the "minimum necessity" principle and uses bank-grade encryption for transmission and storage. All device-related information is securely encrypted via HTTPS and sent to our server at https://api.swiftnaira.com.

By agreeing to and adhering to this Privacy Policy, you explicitly authorize us to collect and process the aforementioned data.

Permissions We Collect and Their Uses

We collect your permission information to assess your application and provide better services. This includes:

Identity Verification

We use your identity-related information (e.g., name, phone number, identification documents) for strict identity verification, ensuring account authenticity and security. Combined with your financial data (e.g., bank account information, income proof) and credit behavior (e.g., repayment history, device usage), we build an accurate credit scoring model that dynamically assesses your credit status and matches suitable loan offers. All basic information obtained will be securely encrypted via HTTPS and sent to our server at https://api.swiftnaira.com.

Location Information

We collect your device’s location information to reduce risks associated with your account and assess information accuracy. We only collect approximate location data, and you are not required to provide precise location information. This information is essential to verify if the user is legitimate, preventing fraudulent logins and activities by bots. Your location data will be securely encrypted via HTTPS and sent to our server at https://api.swiftnaira.com. We will not disclose your information to any unauthorized parties, including illegal organizations, that might trigger local legal requirements.

Emergency Contact Information

During the loan application process, providing emergency contact information is crucial to help us detect potential fraud and reduce bad loan applications, lowering credit risk. The data we collect is limited to the contacts you choose or provide, including their names, phone numbers, and any relevant details about their relationship with you. Your contact information will be securely encrypted via HTTPS and sent to our server at https://api.swiftnaira.com. Due to the importance of your privacy, we will not share this information with third parties without your consent. Once we have assessed your risk profile, we will promptly delete your contact details.

Camera Access

We require access to your device’s camera to capture necessary identification documents for KYC (Know Your Customer) identity verification. Your photo information will be securely encrypted via HTTPS and sent to our server at https://api.swiftnaira.com. We fully understand the importance of data security and will not share any photo information with third parties without your consent.

Device Information

We collect device-related information, such as brand, model, operating system version, network environment, and WiFi data, to prevent actual or suspicious criminal activities. For example, if your account is accessed from another device, we will notify you through the application. Your device information will be securely uploaded to https://api.swiftnaira.com and will not be shared with any third parties.

Application List

We need a list of the metadata of installed apps on your device, including app names, package names, version names, version codes, installation times, and update times. This data will be uploaded to https://api.swiftnaira.com, where we will analyze your creditworthiness and availability based on pre-approved personalized loans.

Google Advertising ID

To enhance our ability to deliver relevant marketing and services and update our records, we may obtain your information from third-party data providers. This includes email addresses, intent data (or user behavior data), IP addresses, social media URLs, and custom profiles, which will be used for targeted advertising and promotional campaigns. This data will be encrypted and stored on our server at https://api.swiftnaira.com and used solely for optimizing advertisement performance and providing better services. Our IT team regularly reviews Swiftnaira’s data security policies, conducting vulnerability assessments and penetration tests. All personal information related to you will be encrypted during storage, transmission, verification, and access restriction processes to ensure data security.

How We Use and Store Your Personal Information

We primarily store your personal information in databases maintained by our service providers, in accordance with relevant financial regulations. This information is used solely to meet your requests or to provide services through the application. We do not share your personal identity information with third parties, unless required to fulfill legal or regulatory obligations. We will take all necessary measures to securely store, process, and transmit your information, in accordance with this policy. We will retain your personal information only for the duration specified in this policy.

Who We May Share Data With

We may share your information with trusted third-party partners when necessary, but we will strictly adhere to data protection principles. These sharing activities are only for legitimate purposes, such as providing and improving our services, fulfilling legal obligations, or protecting legitimate rights. All third-party partners must comply with strict confidentiality agreements and adopt data security standards that are equal to or higher than our own. We will only share the minimum amount of information necessary for service provision and ensure that this information will not be used for purposes unrelated to the agreed-upon uses. You can review data sharing records anytime through your account settings. We are committed to not selling your personal information to any third party without your explicit consent. For example, data may be used for the following purposes:

1. Professional Advisory Institutions - This includes, but is not limited to, law firms, accounting firms, auditing institutions, and other professional consulting services. These institutions will assist us in handling legal matters, such as litigation, contract disputes, intellectual property protection, and conducting financial audits, tax filings, and other professional tasks. In necessary situations, we may provide them with user information related to specific legal or financial matters but will strictly limit the scope of data use and ensure these advisory institutions comply with confidentiality obligations equivalent to ours.

2. Credit Information Agencies - Refers to legally established credit information service institutions, such as commercially authorized credit reporting agencies approved by regulatory authorities. We may query these agencies to assess your loan application or report your repayment behavior (including both regular payments and defaults). This information may be included in the national credit system and may affect your future credit activities with other financial institutions. You have the right to check and correct your credit report through the official channels of these credit agencies.

3. Government Agencies and Law Enforcement - Includes financial regulatory departments (such as the central bank, insurance regulatory commission), judicial authorities, police, and other government agencies authorized to request information by law. We will only provide specific information to these authorities upon receiving legally binding documents (such as court judgments or regulatory investigation letters). Under legal obligations such as anti-money laundering or anti-terrorism financing, we may proactively report suspicious transaction information.

4. Company Transaction Parties - In major business activities such as mergers, acquisitions, asset restructuring, and bankruptcy liquidation, the counterparty, asset valuation institutions, and receivers involved may need access to your information. Information sharing will be strictly limited to the scope necessary for the transaction, and the recipient must sign a confidentiality agreement to continue fulfilling data protection obligations. If the transaction involves significant changes to user rights, we will notify you of the relevant matters and your options at least 30 days in advance through announcements or direct notifications.

How We Delete Your Information

To the extent permitted by law, if your account is terminated or if you believe that we have processed your personal information in violation of this agreement, you have the right to request the deletion of your personal information. You can delete your information through the following methods:

1.You may directly delete your account through the "Delete Account" option available on the app or the app’s official website, but please ensure that you do not have any pending loan orders before proceeding with this action.
2.You may contact customer service directly through the hotline at: 8184250495/8023876735/7050506581/9032523380.
3.You may send an email to Swiftnairahelp@yahoo.com to formally request the deletion of your personal information.
4.You may communicate directly with customer service via the in-app online customer service chat.

Please note that for options “2” and “4”, you should contact us during business hours (Monday to Friday, 9:00 AM - 6:00 PM).

To ensure account security, we will first verify your identity. After verification, we commit to completing the primary data deletion process within 15 business days, including clearing database records, backup data, and notifying our partners to synchronize the deletion. However, some data (such as unsettled loan transactions, anti-fraud information, etc.) may need to be retained for a specified period as required by financial regulatory authorities. Please be aware that the deletion of certain information may cause some services to become unavailable, and any ongoing business must be completed before we process the deletion request. For more details, please refer to our Privacy Policy.

How We Correct Your Information

To the extent permitted by law, if you find that your personal information is incorrect and need to correct your personal data, you have the right to request us to correct it. You can request corrections through the following methods:

1.You may contact customer service directly through the hotline at: 8184250495/8023876735/7050506581/9032523380.
2.You may send an email to Swiftnairahelp@yahoo.com to formally request corrections to your information.
3.You may communicate directly with customer service via the in-app online customer service chat.

Please note that for options “1” and “3”, you should contact us during business hours (Monday to Friday, 9:00 AM - 6:00 PM).

To ensure account security, we will first verify your identity. After verification, we commit to completing the information correction process within 15 business days, including updating system records, correcting relevant data, and notifying necessary partners to synchronize the updates. However, please note that corrections to certain core identity information (such as name, ID number, etc.) may require you to provide additional documentation. Once the correction is completed, we will notify you via your registered email or in the app. For more details, please refer to our Privacy Policy or contact our customer service.

Do We Collect Information from Minors?

We solemnly declare that our application is strictly limited to users who are 18 years old or above. We have established a comprehensive multi-layer verification mechanism, including but not limited to:

1.Mandatory age verification during registration.
2.Regular review of user age information.

If we find any of the following circumstances, we will immediately initiate our emergency data protection procedures for minors:

1.The user is confirmed to be under 18 years old through technical or manual review.
2.We receive valid reports regarding minor users.
3.Regulatory authorities or third-party audits raise concerns about minor users.

The emergency handling process includes:

1.Immediately suspending all functions of the involved account.
2.Completing data verification within 72 hours.
3.Initiating a secure data deletion process for the data of verified minors.
4.Reporting the incident to the regulatory authority.

We commit to conducting at least two specialized audits of minor data protection annually and will file the audit results with the relevant regulatory authorities. Additionally, we continuously improve age verification technologies to prevent minors from fraudulently registering as adults and using our services.

Customer Service Hotline8184250495/8023876735/7050506581/9032523380

EmailSwiftnairahelp@yahoo.com