This Privacy Policy explains how RAY FINTECH LIMITED collects, uses, stores, shares and protects personal information when you use CreditGo, our website, our App, our loan application tools, repayment tools, account services and customer support channels.
1.1 CreditGo is operated by RAY FINTECH LIMITED. In this Policy, "we", "us" and "our" refer to RAY FINTECH LIMITED. "You" refers to the user, applicant, borrower, website visitor or other person who interacts with CreditGo.
1.2 You can contact us about privacy questions, data subject requests or complaints at support@rayfintech.com.
2.1 Account and contact information: name, phone number, email address, account status, login records and customer support information.
2.2 Identity information: date of birth, identification number, Bank Verification Number, government-issued identity document information, selfie, facial image or short liveness video where required for identity verification.
2.3 Loan and financial information: bank account details, loan application information, credit limit information, loan offer details, disbursement records, repayment records, outstanding balance, default status, repayment capacity information, employment or income information and transaction history.
2.4 Device and technical information: device type, operating system, App version, device settings, IP address, network status, time zone, language setting, crash logs, security identifiers, page view statistics and standard web or App logs needed for service operation and security.
2.5 Location information: coarse location, country, state, city, region or IP-based location used to confirm service availability, prevent fraud, support account security and comply with applicable requirements.
2.6 App interaction information: pages viewed, buttons clicked, feature usage, error events and App performance information used for analytics, debugging, service improvement, fraud prevention and product suitability.
2.7 Third-party information: information lawfully received from identity verification providers, banks, Payment Providers, Credit Reference Bureaus, fraud prevention providers, public or official databases, regulatory sources and other authorized service providers.
3.1 CreditGo does not request access to your contact list, call logs, SMS content, photo library, video library, external storage, microphone, precise background location or full list of installed applications.
3.2 We do not collect, scan, upload or share application package names, application usage history, personal data inside other apps, unrelated files, unrelated photos or unrelated media files on your device.
3.3 We do not use contact lists, call logs, SMS content, photo libraries, video libraries, precise background location or installed-app lists for credit scoring, loan recovery or borrower harassment.
4.1 Camera: with your express permission, we may use the in-app camera to capture a selfie, image or short video for identity verification, facial comparison, liveness detection, account security, loan application processing and fraud prevention. Camera access is used only in the foreground when you start the relevant function.
4.2 Location: we may use coarse location or IP-based location to check service availability, confirm that services are used in Nigeria, prevent fraud and maintain account security. We do not request precise background GPS tracking.
4.3 Notifications and communications: we may send App notifications, SMS, email or phone communications for account security, OTP delivery, loan information, repayment reminders, support and service notices. We do not read your SMS inbox or call history.
4.4 You may manage App permissions through your device settings. If you withdraw a permission, some functions, especially identity verification, may not work properly.
5.1 To create and manage your Account, authenticate logins, send OTPs and protect your Credentials.
5.2 To verify identity, complete KYC checks, conduct fraud prevention, confirm eligibility and comply with legal and regulatory obligations.
5.3 To assess credit risk, determine loan eligibility, calculate or review credit limits, present loan offers and support responsible lending.
5.4 To disburse Loans, process repayments, manage outstanding amounts, send repayment reminders and maintain transaction records.
5.5 To provide customer support, investigate complaints, resolve disputes, correct account issues and communicate service updates.
5.6 To improve CreditGo, monitor App performance, debug errors, understand feature usage, prevent abuse and maintain security.
5.7 To report to, receive information from or respond to Credit Reference Bureaus, regulators, courts, law enforcement agencies or other authorized bodies where permitted or required by law.
6.1 We process personal information where it is necessary to provide the Services or perform a contract with you.
6.2 We process personal information where needed to comply with legal, regulatory, accounting, tax, anti-money laundering, consumer protection, credit reporting, fraud prevention or record-keeping obligations.
6.3 We may process information where we have a legitimate interest, such as securing the Platform, preventing fraud, improving services, managing risk, enforcing agreements and responding to disputes, provided that such interest is not overridden by your rights under applicable law.
6.4 Where applicable law requires consent, we will request consent before processing, and you may withdraw consent subject to legal, contractual and service limitations.
7.1 We do not sell your personal information.
7.2 We may share only the information necessary for the stated purpose with banks, Payment Providers, identity verification providers, BVN verification providers, Credit Reference Bureaus, fraud prevention providers, analytics providers, customer support providers, cloud or technology providers, recovery service providers, professional advisers, affiliates, regulators and other authorized recipients.
7.3 We may share repayment behavior, defaults, outstanding obligations and other credit-related information with Credit Reference Bureaus, regulators or authorized credit reporting systems, subject to applicable law.
7.4 We may disclose information where required by law, court order, regulatory instruction, law enforcement request or other lawful authority.
7.5 We require service providers to use information only for authorized purposes, protect it with appropriate safeguards and comply with applicable confidentiality and data protection obligations.
8.1 Our website, App and service tools may use cookies, SDKs, web beacons, logs and similar technologies for security, analytics, App performance, debugging, fraud prevention and service improvement.
8.2 We may use providers such as AppsFlyer and Google Firebase for analytics, attribution, crash reporting, performance monitoring, fraud prevention and product improvement, limited to what is necessary for those purposes.
8.3 You may manage browser cookies or device permissions through your browser or device settings. Disabling some technologies may affect service functionality.
9.1 We primarily process and store personal information in accordance with applicable Nigerian data protection requirements.
9.2 Where personal information is transferred outside Nigeria, we will take steps required or permitted by applicable law, which may include contractual protections, transfer assessments, security safeguards, regulatory approvals where required, or your consent where applicable.
10.1 We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.
10.2 Account information may be retained while your Account is active and for a reasonable period after closure for legal, audit, security, dispute resolution and fraud prevention purposes.
10.3 Loan, repayment, transaction, credit reporting and financial records may be retained for periods required by law, accounting requirements, audit requirements, regulatory obligations, dispute resolution and enforcement needs.
10.4 Identity verification, fraud prevention and security records may be retained for as long as needed to prevent fraud, comply with obligations and protect users and the Platform.
10.5 Analytics and technical logs are retained for a limited period necessary for security, debugging, analytics and service improvement, unless a longer period is needed for investigation, compliance or dispute resolution.
11.1 We use technical and organizational measures designed to protect personal information against unauthorized access, alteration, loss, misuse, disclosure and destruction.
11.2 These measures may include encryption, access control, authentication controls, data minimization, de-identification, monitoring, secure transmission, audit procedures and employee or service provider access restrictions.
11.3 No internet, mobile or electronic service is completely secure. You should protect your Credentials, use strong passwords or PINs, keep your device secure and notify us promptly if you suspect unauthorized access.
11.4 Where a personal data breach occurs and notification is required by law, we will take appropriate steps to notify affected persons and/or regulators in accordance with applicable requirements.
12.1 Subject to applicable law, you may have the right to request access to your personal information, correction of inaccurate information, deletion, restriction of processing, withdrawal of consent, objection to certain processing, data portability where applicable, and review or explanation of decisions that significantly affect you where applicable law provides such right.
12.2 We may need to verify your identity before responding to a request. Some requests may be refused, limited or delayed where required or permitted by law, including for fraud prevention, legal claims, regulatory compliance, accounting, audit, security or protection of another person's rights.
12.3 To exercise privacy rights, contact us at support@rayfintech.com. We will respond within the period required by applicable law, and in normal cases aim to respond within 15 days after receiving sufficient information to verify and process your request.
13.1 CreditGo is not intended for persons under 18 years old. We do not knowingly provide Loans to minors. If we become aware that a minor has provided personal information, we will take appropriate steps in accordance with applicable law.
14.1 We may update this Policy from time to time. Where a change is material, we will use reasonable efforts to notify users through the App, website, email, SMS or another appropriate channel.
14.2 The updated date and effective date at the top of this Policy show when this Policy was last revised and when it applies.
RAY FINTECH LIMITED
Email: support@rayfintech.com
Website: https://rayfintech.com/
