PRIVACY POLICY

We are registered under the name Abadi Technology LTD in Nigeria and has registered our office at Mopelola House, Jully Estate, Ikeja, Lagos State,Nigeria.

We are a company legally established and regulated according to Nigeria law. We fully comply with all applicable laws.

Thank you (hereinafter referred to as “you” “your” or “User“) for choosing Singacash by Abadi Technology LTD (hereinafter referred to as “Singacash” “Platform” “we” “our” or “us“).

This Privacy Policy is made to protect and maintain the privacy and confidentiality of the Platform Users. Users are expected to read this Privacy Policy carefully before using Our Services provided in this Platform. This Privacy Policy does not apply to any websites or mobile applications which are not operated by us that you may access via the Platform. Such services are governed by the privacy policies appearing on those sites and applications. Depending upon your relationship with us, you may receive other privacy notices from us providing additional detail about Our privacy practices. By accessing and using the Services provided in the Platform, Users acknowledge that they have read, understood and agreed to the content written in this Privacy Policy and the Platform’s terms of use.

IF YOU DO NOT AGREE ON THE PROCESSING OF YOUR PERSONAL DATA BASED ON THIS PRIVACY POLICY, PLEASE DO NOT PROVIDE ANY PERSONAL DATA WHEN REQUESTED BY US AND IMMEDIATELY STOP USING OUR PLATFORM AND LEAVE OUR PLATFORM. BY CONTINUING TO USE AND ACCESS OUR PLATFORM OR PROVIDING ANY PERSONAL DATA, YOU ARE ACKNOWLEDGING AND AGREEING TO THE PROVISIONS REGARDING YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY.

DATA INFORMATION

PERSONAL INFORMATION COLLECTION, USAGE AND DISCLOSURE

When you create an Singacash account through the Singacash application or website, or access the Singacash Application via GooglePlay, Appstore, or other download platform (“Platform”), you may be asked to provide or provide information, from time to time,

Our Platform collects Personal Data to provide, maintain, and improve our Services, as well as to process all forms of requests, instructions, activities, transactions carried out by User, and/or for other purposes as long as permitted by applicable laws and regulations. If you fail to provide such data as required, we may not be able to provide the service as intended. The Personal Data we may collect from Users are as follow:

  1. Personal/Contact Information: Name, email address, city of residence, current address, company address, phone number and emergency contact. 
  2. Identification Data: NIN Photo, , Tax ID, mother’s maiden name, facial photo, marital status, property ownership, education, civil status, industry and occupation, working period, city of work.
  3. Financial Information: Bank account details, virtual account, credit history, and income information (salary release date and monthly income), loan purpose, loan status from other third party.
  4. Technical Data and Features (including but limited to): device ID, mobile operating system, mobile operating system version number, mobile phone manufacturer, operator, mobile phone model, network type, mobile phone system language, IP address, MAC address, geographical location, domain name, camera, microphone, Installed Application information (Android only), resolution rate, longitude, latitude, IMEI, mobile advertising identifier.

For Installed Application information, if you agree we can collect your Installed Application information, please click “Agree” on the homepage and during borrowing and repayment process. If you do not agree, please click “Reject”. Your choice will not affect your use of Platform.

In addition to the information above, we can also collect additional information in order to provide services and improve the quality of our services, including the information you provide when contacting our customer service team, including the questionnaires that you filled out during the Loan survey. In order to improve the security of the use of the Singacash services and to provide a more precise and effective prevention of fraud and virus threats, we may understand some of your habits in using networks, software information that you use often and other ways to determine Account risk, and record some URLs that we think are risky.

We will/may collect, store, use, disclose and/or process Your Personal Information for the following purpose(s) of:

  1. appraisal, analysis, identification and verification, validation or examination of (i) Loan Application; (ii) process or application for registration as a Lender or Borrower; and/or (iii) Your profile;
  2. conducting Identification and verification, risk assessments, statistical analysis and planning and trends, including carrying out data Processing, statistical analysis, credit, risk and anti money laundering screening, creating and managing credit assessment models, conducting credit checks, reviews and other backgrounds checks and keeping history of your credit for current and future reference;
  3. Manage our relationship with you which may include providing information to You regarding the Platform and allowing you to use the services provided by the Platform, such as for the following matters:
    • contacting you regarding your request or the needs;
    • for our business needs in general, including verifying your identity and credit reputation;
    • identifying you when you contact us or visit the Platform;
    • providing adequate information stored on the Platform to identify you to the Lender and/or Borrower;
    • allowing banks, financial entities or authorized third parties to carry out confirmation regarding Your status in our database or services (if required);
    • handling questions or complaints made by or related to you in connection with the Platform and stored to prevent and detect any fraud, infringement and other potential misuse from occurring;
    • verifying your compliance with the terms and conditions governing the use of the Platform;
    • managing the User’s escrow account to the escrow account provider;
    • notifying you regarding any changes to the Platform and services;
    • allowing you to participate in our interactive feature services.

PRODUCT DEVELOPMENT AND IMPROVEMENT

  1. to send you relevant promotional materials and updates about our Services. We may use your data to tailor marketing communications based on your interests and preferences;
  2. to analyze user behavior and preferences, and enhance our Platform’s performance in a most effective way for you through our Platform;
  3. to opt out of use of data for the above purpose, please contact www.singa.ng.

COMPLIANCE AND TO PROTECT US FROM LEGAL CLAIMS

  1. to identity, verify, and conduct risk assessment in accordance with the relevant laws and regulation on Anti-Money Laundering and Counter Financing of Terrorism;
  2. to comply, fulfill the requirements from applicable laws and regulations, authorized institutions such as Central Bank of Nigeria, and Court orders and other regulators that apply to us;
  3. to monitor, detect, prevent and investigate suspicious transactions or transactions that are indicated to contain elements of fraud, crimes or violations of the Terms and Conditions or applicable legal provisions, as well as taking necessary actions as a follow-up to the results of monitoring or investigating such transactions;
  4. to processing necessary to fulfil Users’ and our obligations under the Platform Agreements and other relevant documents;
  5. to processing necessary for our legitimate interests or those of third parties, provided your fundamental rights are not overhidden;
  6. to processing based on your explicit consent for specific purposes. You have the right to withdraw your consent at any time;
  7. processing necessary to comply with our legal obligations.

DISCLOSURE OF PERSONAL DATA

We are committed to maintaining the confidentiality of Personal Data which is under Platform’s control and we guarantee no disclosure, sale, transfer, distribution, and/or lending of Personal Data to other third parties, without the consent of the User. You agree that we may share your personal information with the following parties, including but not limited to:

  1. Lenders
    for loan facilitation purposes;
  2. Service providers
    third-party companies that help us to provide services or to perform data processing for and on behalf of us or for the implementation of Users’ credit worthiness analysis (e.g., payment processors, credit bureaus, identity verification service providers, IT service providers, e-signature service providers, telecom operators, insurance companies, etc.).
  3. FinTech Association of Nigeria (FinTechNG)
    governed by FinTech Association of Nigeria (FinTechNG) for the purpose of credit data reporting;
  4. Legal and Regulatory Authorities
    in response to compliance requirements by the Central Bank of Nigeria, legal requests, court orders, or to protect our rights or safety;
  5. Collection Vendor & Business Partners
    for debt collection, channeling cooperation, joint marketing cooperation, and/or other parties relevant to our business operations;
  6. Management, Employees and Affiliated Companies of Singacash
    for the implementation of Services; for merger, acquisition, transfer of assets, and/or other corporate restructuring activities or in connection with one or more purposes as set out in this Privacy Policy.

We may need to disclose Personal Data to third-party service providers, agents, our affiliated companies, and/or other third parties located outside the territory of the law of Nigeria. Nonetheless, such third-party service providers, agents, and/or affiliates or related companies and/or other third parties shall only manage and/or utilize Personal Data in connection with one or more purposes as set out in this Privacy Policy and in accordance with applicable laws and regulations.

SMS PERMISSIONS AND FILTERED MESSAGE CONTENT

With your explicit consent, our application may access SMS messages stored on your device solely for the purposes of credit risk asessment and fraud detection during the loan application and repaymnet process;

Scope of Access, we only access SMS Messages located in your device’s inbox folder, we don’t access Sent,Drafts,Outbox or any other folders, we only scan messages that contain the following exact keywords (case-insentive,whole-word match): loan, credit, overdue, due on, approved, disbursed, over due, refuse to pay, failed to pay, fail to pay.

No other SMS Content is collected, parsed or stored.

Purpose of Use, collected messages are used only for automated risk assessment and anti-fraud verification, the information will never be used for marketing, profiling or advertising purposes.


Data storage & Retention, we store only the minimum data required, including: the full text of the matched SMS,timestamp of receipt, originating phone number (if needed for verification), data is stored temporarily and will be retained no longer than 30 days after the loan decision, unless a longer retention period is required by law or regulatory authority.

Deletion & Revocation, you may revoke SMS access at any time via application or device settings, Upon revocation; All Scanning activities will stop immediately and any previously stored SMS data will be permanently deleted, unless retention is required by applicable law, SMS data is also permanently deleted when you request account deletion or when the retention period expired, deletion is irreversible and logged for audit purposes.

User rights, granting SMS access is voluntary, if you deny SMS access you may continue using our platform; however, our ability to assess your creditworthiness may be limited.

SECURITY AND DATA RETENTION

  1. We will take all reasonable steps and actions to prevent the loss, misuse or unauthorized changes of Your Personal Information by unauthorized parties.
  2. Whilst We take necessary steps and precautionary actions to prevent unauthorized entry or use, and hardware or software failure, these situations may happen and potentially compromise the security of Your Personal Information. We hereby disclaim, to the fullest extent permissible by law, any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorized access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any Personal Information provided by you to us.
  3. When registering yourself on the Platform, you are requested to create your own personal password. you are responsible for maintaining the confidentiality of this password. You must not share your password with anyone.
  4. We are certified and compliant with Cyber Security and we implement appropriate security measures to protect your Personal Data from unauthorized access, usage, modification, disclosure, or destruction by using certain security measures and procedures, including the use of encryption, firewalls, Users passwords and OTP (One Time Password) codes, and other technology to safeguard your Personal Data.
  5. Personal Data may also be stored or processed outside Nigeria territory by parties working for us in other countries, or by third party service providers, vendors, suppliers, partners, contractors or affiliated companies. In this case, Singacash will ensure that Personal Data remains protected in accordance with Singacash commitment in this Privacy Policy.
  6. We retain your Personal Data for as long as necessary to fulfil the purposes outlined in this policy, at least until 5 years after you terminate your use of our Platform, or as required by law. Upon expiry, we will securely delete or anonymize your data if: Personal Data is no longer required to fulfil the purpose for which it was collected; and (ii)storage is no longer required for the purpose of compliance with the applicable laws and regulations. However, you may request for deletion of your Personal Data at all time, by submitting request to our customer service. Deletion of your Personal Data does not affect the lawfulness of processing and your obligation that was carried out before the deletion. User hereby understand that the impact of deleting User’s Personal Data from Singacash system will result in closure of your Singacash account. 

ACCOUNT DELETION

  1. You have the right to request deletion of your account at any time.
  2. To delete your account, go to the “Account” page in the Singacash application, tap “Settings”, then select “Delete user account”.
  3. A confirmation prompt will appear; tap “Yes, delete it” to confirm or “No, keep it” to cancel.
  4. Once confirmed, your account and associated data will be permanently deleted, unless we are required to retain certain data for legal or regulatory reasons.
  5. Alternatively, you may contact our customer service team for assistance. Send an email to cs@singa.ng with your registered mobile number and any information that can verify your identity as the account owner. Once verified, we will proceed to delete your account.

THE USAGE OF REGISTERED CONTACT

  1. The Registered Contact provided by the Borrower during the process of submitting the Loan application (“Loan Application”) will be used for contacting the Registered Contact when the Borrower is classified as being in Failure of Payment.
  2. As an absolute requirement for a Loan to be made through the Platform, the Borrower hereby authorizes us, and represents that it has obtained prior consent from the Registered Contact—without requiring further approval of any other party—to contact the Registered Contact in the event that the Borrower is classified as being in Failure of Payment, for the following purposes:
    1. to search or track the location of the Borrower in the event that the Borrower has not paid the Loan and cannot be contacted at his/her registered cellular telephone number recorded with the Platform during the Loan Application process;
    2. to request assistance from the Registered Contact to remind the Borrower to pay and settle the Loan; and/or
    3. to request the Registered Contact to deliver the message from us in connection with the fulfillment of the Loan repayment obligation and the Failure of Payment.
  3. We shall contact the Registered Contact for the above purposes either through direct calls, SMS (Short Message Service), WhatsApp, and/or other communication methods as determined by us from time to time with due observance to the provisions of the prevailing laws.

LIABILITY RELEASES

The Borrower hereby releases, defends and indemnifies Us and the Lender (along with Our and the Lender’s employees, directors, commissioners, shareholders, representatives, attorneys, agents and/or affiliates) from any claims, liabilities, losses, expenses, costs or fees arising from or in connection with the following:

  1. any dispute with a third party regarding a Registered Contact for any reason;
  2. violation of rights or losses of third parties or any parties related to the Registered Contact; and
  3. sanctions, research, investigations, inspections or audits as well as any consequences of or relating to violations of legal provisions and/or legislation, government policies and/or judicial and/or arbitration decision resulting from or in connection with the implementation of Our rights herein or attempts to contact, access, browse, obtain and/or utilize a Registered Contact.

FAILURE IN PROTECTING PERSONAL INFORMATION

You agree not to seek our responsibility for violations, or non-compliance with the Privacy Policy or the protection of Personal Information in the following situations:

  1. Force Majeure or where an act of nature or an unexpected situation has occurred, resulting in damage or destruction of equipment and/or systems which are used to secure, store, or process a User’s Personal Information;
  2. Where Personal Information is available or can be found by the public before such Personal Information has been conveyed by us;
  3. Where we have given our best effort to verify, secure, and protect the Personal Information, and in the event of any unauthorized access, hacking, misuse, modification, change, or interference;
  4. For the accuracy (unless for Personal Information that has been verified by us at our discretion), validity, legality, and completeness of your Personal Information; and/or
  5. Where the misuse of Personal Information and information is caused by acts of crime, fraud, or any criminal act or illegal action of a third party that is not under our control or instruction.
  6. We will make reasonable efforts to notify you in writing via e-mail if there is a failure in our protection of Personal Information during the management of the Platform, whether caused by us or a third party, with the following notification conditions:
    1. by including the reason or cause of the failure in the protection of Personal Information;
    2. written notification via e-mail to you no later than 14 (fourteen) days after the failure is discovered;
    3. providing a contact person who can be easily reached by you regarding the management of Personal Information.

COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

Any matter or situation not expressly governed by this Privacy Policy shall be subject to applicable laws and regulations. We will adhere to all legal requirements and obligations as mandated by the authorities to ensure the protection and proper handling of your personal data. In cases of any inconsistency between this Privacy Policy and the law, the latter shall prevail.

PRIVACY POLICY CHANGES

  1. This Privacy Policy may be changed and/or updated from time to time. We will publish the latest version of this Privacy Policy on the Platform.
  2. You are advised to carefully read and check this Privacy Policy from time to time so that you remain informed about the latest version of this Privacy Policy.
  3. We may notify you of changes made to this Privacy Policy via e-mail to your registered e-mail address.
  4. By continuing to access and use the Platform and Services, you agree to any changes to this Privacy Policy.

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Risk Disclosure Statement

  1. Nature of Agreement
    Funding services provided via this platform constitute a private contractual agreement between the Lender and the Borrower. All risks, liabilities, and obligations arising from the agreement are entirely the responsibility of the respective parties involved.

  2. Credit Risk
    The Lender bears full credit risk, including the possibility of default by the Borrower. No governmental authority, including the Central Bank of Nigeria (CBN), guarantees the repayment of any funding or assumes any liability in the event of default.

  3. Data Privacy and Consent
    By using this platform, Users consent to the collection, storage, use, and processing of their personal data by the Operator in accordance with the Nigeria Data Protection Act (NDPA) and other applicable regulations. Users will be informed about the purpose, scope, and mechanism of data utilization prior to granting consent.

  4. User Suitability
    Individuals who lack adequate understanding, financial experience, or risk tolerance concerning lending and borrowing are strongly advised not to use this service. Participation is at the User’s own risk.

  5. Loan Affordability
    Borrowers are urged to carefully assess their ability to repay, taking into account the interest rates and all associated fees before applying for a loan.

  6. Fraudulent Activities
    All fraudulent behavior is logged digitally and may be publicly traceable. The Operator reserves the right to take appropriate legal action, including reporting to law enforcement or regulatory authorities.

  7. Informed Decision-Making
    Users must thoroughly read, understand, and accept the platform’s terms and conditions, as well as this Risk Disclosure Statement, before entering into any funding or borrowing agreement.

  8. Regulatory Compliance
    The Central Bank of Nigeria and other regulatory bodies shall not be held liable for any actions or omissions by Users (either intentional or negligent) that contravene existing laws, regulations, or terms of agreement between Users and the Operator.

  9. Transaction Channels
    All funding and loan disbursements must be executed via licensed Nigerian financial institutions, in accordance with CBN regulations on funds transfer, anti-money laundering (AML), and know-your-customer (KYC) obligations.

    About the Company
    ABADI TECHNOLOGY LTD is a legally registered entity in Nigeria, operating in compliance with applicable Nigerian corporate and financial services laws. The Company is duly registered with and operates under the supervision of the Central Bank of Nigeria (CBN).
    The Company functions solely as a technological intermediary, facilitating connections between lenders and borrowers. It does not engage in lending activities itself, nor does it provide financial advice or investment recommendations.
    All services provided through the platform are administrative in nature, and any funds transferred through the platform are not considered deposits as defined under the Nigeria Deposit Insurance Corporation (NDIC) or other applicable banking laws.

    Disclaimer:
    All information presented on the platform or website, including any promotional or informational materials, does not constitute an offer, solicitation, or recommendation to invest in securities or financial instruments. Users act on their own judgment and are responsible for complying with all applicable laws and regulations.

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