Privacy PolicyLast Updated: September 27, 2021
This Privacy Policy (the “Policy”) governs the use of your personal information on our platform, including any website or software (the “Site”) for accessing the platform, and any services provided through the platform (collectively, the “Platform”) (the “Services”) provided by Evolve Credit (the “Company”, “Evolve”, “we”, “us” or “our”). Evolve takes your right to privacy seriously. You have a right to know what we do with your personal information so that you can make informed choices while visiting our website.We recommend that you read our Privacy Policy carefully to understand our views and practices regarding your personal data and information, its collection and usage. By accessing and using our Platform and or Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional "just-in-time" disclosures or information about our data processing practices. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.You agree to indemnify us and hold us harmless of the release of any personal data pursuant to our Privacy Policy. This Privacy Policy describes the way in which the company deals with the information and data you provide to us to enable us to manage your relationship with us. We will process any personal information provided to us via the Platform and other related means.Your personal data will not be disclosed to third parties, unless such disclosure is necessary for processing of your request, such as creating an account on the Platform (the “Evolve Account”), effecting transactions on your Evolve Account or to carry out verification procedures.
  1. What information do we collect?
  2. Why do we process your Personal Information?
  3. Use of your Personal Information
  4. Your Privacy Rights
  5. Security of your Personal Information
  6. Use of Cookies
  7. Disclosure of Information
  8. Retention of Information
  9. Third Party Sites and Services
  10. Telephone Calls
  11. Changes to our Privacy Policy
  12. Contact Us
  1. What information do we collect?
    2. Your Personal Information is processed subject to and in accordance with the requirements of the Nigeria Data Protection Regulation 2019.We may collect the following types of information from you:Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email. Information you provide to us by filling in the forms on the website or any other information you submit to us via the website or email.Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under Financial or Anti-Money Laundering Laws.Financial Information: Bank account information, Payment card details, Transaction history, trading data, and/or tax identification. Details of the transactions you carry out with us via the Site, including details of payment methods used.Business Information: Full name of your business with registration details, incorporation documents, Tax ID number, country of operations, details of Directors and shareholder with valid means of identification, signature, utility bills, photographs of promoters their phone numbers, emails, and home addresses. These Information are required to be provide to us by filling in the forms on the website or any other information you submit to us via the website or email.Information we may collect from you automatically: To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
    • Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
    • Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies. Details of your visits to the website including, but not limited to, location data, weblogs and other communication data.
    Other information and data about you which we may collect, use, and process include the following:
    • Records of correspondence received via the website, email and telephone.
    • Your responses to surveys or customer research that we carry out from time to time.
    • Details of the transactions you carry out with us via the website, telephone or other means, including details of payment methods used.
  2. Why do we process your Personal Information?
    3. We collect and process personal information and sometimes personal information to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering Laws and regulations.Legal Basis for our use of Personal Information.We use your Personal Information to furnish our contract with you, thus when we provide you with products or services or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments.
  3. Use of your Personal Information
    4. Evolve Credit uses the information collected for the following purposes:We may use your personal information and data together with other information for the purposes of processing, operating and managing your access to our Site.
    • To maintain legal and regulatory compliance: Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Evolve must identify and verify customers using our Services in order to comply with Anti-Money Laundering laws across jurisdictions. This includes collection and storage of your photo identification. In addition, we may use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records.
    • Regularly providing you with information about promotional offers, products and services.
    • To provide customer service: We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
    • To ensure quality control: We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
    • To ensure network and information security: We process your personal information in order to enhance security, monitor and verify identity or service access, combat other malware or security risks, and to comply with applicable security laws and regulations in our jurisdiction.
    • For any purpose that you provide consent: We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or Evolve Services may not be available to you.Evolve will also process your personal data for the purposes of carrying out verification procedure in relation to your use of the services provided on the Site. We may also use your information to improve our products and services and track /target the interest of our users so that we can enhance user experience.
  4. Your Privacy Rights
    5. Your rights to personal information are not absolute. Nonetheless, you have the right to the following:
    • Right to be informed – to know what personal data is collected about, and how long it is kept.
    • Right to Access
    • Right to Rectification - you can request the rectification of your Data which are inaccurate, and also add to it. You can also change your personal information in your Account at any time.
    • Right to object to processing
    • Right to Restrict processing - in certain circumstances, you have the right to limit the processing of your data.
    • Right to Data Portability.
    • Right to be Forgotten or Deletion.
    Kindly note that these rights are not absolute, for example some financial information with respect to clause (c), may not be rectified such as Means of ID, Financial history etc. Clause 4(d) will not extend to KYC and verification procedures. While Clause 4(g) is subject to Clause 8 to the extent that it relates only to transaction history.
  5. Security of your Personal Information
    1. Evolve secures your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption through a security protocol on the Website.
    2. Information Storage and Protection
      Evolve will take all reasonable steps to ensure that your information is secured and protected. We will only disclose personal information to other companies within associated or subsidiary companies and to business partners; successors in title to our business and suppliers that are engaged to process such information on our behalf. If you apply for an account with us then to help us make credit decisions about you, to prevent fraud, to check your age and identity and to prevent money laundering, we may use third parties including credit reference agencies who will record any searches on your file. We may also make enquiries of, and disclose details of how you conduct your account to such agencies, security organizations and any other relevant third parties for fraud and money laundering prevention.However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in the “Contact Us” section below.
  6. Use of Cookies
    7. In order to make your visit to the Website user-friendlier, to keep track of visits and to improve the service, the company collects a small piece of information sent from your browser, called a cookie. If you register with us or if you continue to use the website you agree to our use of cookies. We utilize cookies to help manage player logins, to protect against security issues, and to remember player preferences. We do not set a persistent cookie to store your passwords, as we do not want anyone to be able to access your account other than you. We will take all reasonable steps to ensure that your information and data is treated securely and in accordance with this Privacy Policy.
  7. Disclosure of Information
    8. Evolve will disclose your personal information, without notice, only if required to do so by applicable law, regulation, operating agreement, legal process or in the good faith or belief that such action is appropriate and necessary to:
    • Conform to the law or comply with legal processes served on Evolve or the site;
    • Protect and defend the rights or property of Evolve and,
    • Act under exigent circumstances to protect the personal safety or property of users of Evolve, or the public in the event of a claim or dispute to your use of our services. You hereby consent to such disclosures. All such information will be held in accordance with this Privacy Policy.
  8. Retention of Information
    9. We store your personal information and Business Information securely throughout the extant functionality of your Evolve Account. We will only retain your Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below: Information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.Recording of our telephone calls with you may be kept for a period of up to six years. Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from the expiry of the cookie.
  9. Third Party Sites and Services
    10. If you authorize one or more third-party applications to access your Evolve Services, then information you have provided to Evolve may be shared with those third parties. A connection you authorize or enable between your Evolve account and a third-party account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, Evolve will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using Evolve Services.Please note that third parties you interact with may have their own privacy policies, and Evolve is not responsible for their operations or their use of data they collect. Information collected by third parties, which may include such things as contact details, financial information, or location data, is governed by their privacy practices and Evolve is not responsible for unauthorized third-party conduct. We encourage you to learn about the privacy practices of those third parties.Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. Please review the privacy notice of any third party that will gain access to your personal information. Evolve is not responsible for such third-party conduct.
  10. Telephone Calls
    11. Telephone calls to and from our Customer Contact Centre are recorded for training and security purposes along with the resolution of any queries arising from the service you receive.
  11. Changes to our Privacy Policy
    12. We may update this policy from time to time to reflect your feedback as well as that of the Company. You are encouraged to periodically review our Privacy Policy so as to remain informed of how your information is protected.Any changes we may make to our Privacy Policy in the future will be posted on this page and any such changes will become effective upon posting of the revised Privacy Policy. If we make any material or substantial changes to this Privacy Policy we will endeavor to inform you by email, notice on the website or other agreed communications channels.We may enforce material changes to the Privacy Policy without your express consent. If you decline to accept the changes to the Privacy Policy or otherwise do not accept the changes within the time period, we may not be able to continue to provide some or all services.
  12. Contact Us
    13. Evolve welcomes your comments regarding our Privacy Policy. If you have any concerns or would like more detail about how we process your personal information, you can contact us at support@evolvecredit.co.
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