Privacy Policy
This Privacy Policy (hereinafter referred to as "Policy") sets forth the terms and conditions under which Digitaldelight Integrated Support Service Ltd and its licensed platform Pure Cash (hereinafter referred to as "the Company" or "Pure Cash") collects, uses, stores, discloses, and safeguards the personal information of users (hereinafter referred to as "you" or "User") in connection with your access to and use of the Pure Cash website, mobile application (hereinafter collectively referred to as the "App"), and any other services provided by the Company (hereinafter collectively referred to as the "Services").
Acceptance of Terms
By registering an account, submitting any application, or continuing to use the Services in any manner, you expressly acknowledge and agree that you have read, understood, and consent to be legally bound by all terms and conditions of this Policy. If you do not agree to any part of this Policy, you are required to immediately discontinue your use of the Services.
1.Definitions
i) "Company" refers to the legal entity providing the Services.
ii) "Personal Information" means any data or information that, directly or indirectly, identifies or can be used to identify an individual.
iii) "Account" means the unique user account created by you to access or use the Services.
2. Consent to Processing
By providing your Personal Information to the Company and/or by accessing or using the Services, you expressly consent to the collection, processing, storage, and transfer of your Personal Information in accordance with this Policy. You acknowledge and accept that such processing is necessary for the provision of the Services and that the Company may take all reasonable measures to ensure the confidentiality, integrity, and security of your Personal Information.
3. What Personal Information We Collect
In connection with your use of the Services, the Company may collect, process, and maintain certain personal information that is necessary for the provision, operation, and improvement of the Services. The types of personal information collected depend on the Services you use, the features you access, and the permissions you provide. Such information may include, but is not limited to, identifying details, contact information, financial and employment-related data, user preferences, and information regarding your interaction with the Company's website, mobile application, products, and services.
The collection and processing of your personal information are conducted in accordance with applicable laws and regulations, and only to the extent necessary for the legitimate purposes of providing, maintaining, and enhancing the Services, preventing fraud, and ensuring the security and integrity of your Account. By using the Services and providing your information, you consent to such collection and processing in accordance with this Policy.
3.1 Sensitive Information:
Subject to your explicit consent and to the extent permitted by applicable laws, we may collect, process, and use certain categories of sensitive personal information for purposes including identity verification, credit assessment, fraud prevention, account security, and compliance with applicable regulatory requirements. Such information is collected in a limited, necessary, and proportionate manner as described below:
(a) SMS Data
With your explicit consent, we may access certain SMS messages for the purposes of verifying income stability, assessing repayment capacity, and preventing fraudulent activities.
Access is strictly limited to SMS messages related to financial transactions, including but not limited to bank alerts, salary deposits, loan repayments, and payment confirmations. We do not access, collect, or store personal or non-financial SMS content.
All SMS data is transmitted securely using encryption and stored on secure servers operated by us, including but not limited to https://frontend.ddigitaldelight.com.
We do not sell, rent, share, or disclose such information to advertisers or any unrelated third parties.
You may withdraw or disable this permission at any time through your device settings; however, certain features of the Services may not function properly without such access.
(b) Device Information
We may collect certain device-related information to uniquely identify your device, prevent fraud or misuse, and improve the accuracy of your user profile for risk assessment and service optimization.
Such information may include operating system version, device model, system version, basic hardware usage data, and advertising identifiers provided by third-party service providers.
All data is transmitted securely using encryption and stored on secure servers operated by us, including but not limited to https://frontend.ddigitaldelight.com.
(c) Emergency Contact Information
With your consent, we may collect limited emergency contact information to facilitate communication where we are unable to reach you directly, and to support credit assessment and risk management processes.
The information collected is strictly limited to contact names and mobile phone numbers. We do not access or collect your full contact list.
All such information is transmitted securely using encryption and stored on secure servers operated by us, including but not limited to https://frontend.ddigitaldelight.com.
We do not disclose such information to any third party without your explicit consent, unless required by applicable law.
(d) Approximate Location Information
With your consent, we may collect approximate location information to verify usage consistency, prevent fraud, and comply with applicable legal and regulatory obligations.
We only collect general network-based location information and do not access precise or real-time GPS location data.
All location data is transmitted securely using encryption, stored on secure servers operated by us, including but not limited to https://frontend.ddigitaldelight.com, and automatically deleted upon account termination.
We do not sell, rent, or disclose such data to any third parties.
(e) Installed Applications Information
We may collect limited information regarding applications installed on your device for fraud prevention, risk assessment, and account security purposes.
Such information may include application names, categories, installation dates, and version information.
This data is used solely for security and fraud detection purposes and is not disclosed to advertisers or unrelated third parties.
(f) Application Usage Information
With your consent, we may collect limited information regarding your usage of certain applications for the purpose of detecting abnormal behavior, preventing fraud, and promoting responsible use of financial services.
This may include usage frequency and duration of selected applications. Applications unrelated to financial activities are not monitored.
All such data is processed securely in accordance with applicable data protection standards and is not shared with advertisers or unrelated third parties.
(g) Calendar Information
With your consent, we may access limited calendar information to assist in financial management and repayment assessment.
Such information is limited to event titles, dates, and times.
All data is encrypted during transmission, stored securely, and used solely for the stated purposes. It is not used for marketing or advertising purposes.
You may revoke this permission at any time through your device settings.
(h) Phone State Information
We may collect limited phone state information, including SIM card details, carrier information, and network status, for the purposes of account security, fraud detection, and prevention of unauthorized activity.
All such data is transmitted securely using encryption and used exclusively for security-related purposes.
4. Cookies Policy
4.1 Purpose of Cookies
We use cookies and similar tracking technologies to ensure the proper functioning of our Services, enhance security, improve performance, and provide a more consistent and personalized user experience.
Cookies enable us to recognize returning users, maintain session continuity, store user preferences, and analyze how users interact with our website, mobile application, and related services.
4.2 Data Collected Through Cookies
When you access or use the Services, certain cookies may be automatically stored on your device.
These cookies may collect limited technical and usage information, including but not limited to IP address, device identifiers, browser type, operating system, language preferences, and pages or features accessed.
Such information is collected for operational, analytical, and security purposes only.
4.3 Types of Cookies We Use
We use the following categories of cookies depending on their purpose:
(a) Essential Cookies
These cookies are strictly necessary for the operation of the Services and enable core functionality such as security, authentication, and system stability. The Services cannot function properly without these cookies.
(b) Performance and Analytics Cookies
These cookies help us understand how users interact with the Services by collecting aggregated and anonymized usage data. This allows us to improve functionality, performance, and user experience.
(c) Functional Cookies
These cookies enable the Services to remember user preferences and settings, such as language selection and interface customization, to provide a more personalized experience.
(d) Advertising and Measurement Cookies
Where applicable and subject to consent requirements under applicable laws, these cookies may be used to measure the effectiveness of campaigns and deliver relevant content. Data collected through such cookies is processed in aggregated or pseudonymized form.
4.4 Cookie Management
You have the right to manage or disable cookies at any time through your browser or device settings.
You may choose to block all cookies, accept only certain categories, or configure your browser to notify you when cookies are being used.
Please note that disabling certain cookies may affect the availability, functionality, or performance of some features of the Services.
4.5 Updates to This Policy
We may update this Cookies Policy from time to time in order to reflect changes in legal, technical, or operational requirements.
Any updates will become effective upon publication. Your continued use of the Services after such updates constitutes your acknowledgment and acceptance of the revised Cookies Policy.
5. How We Use Your Personal Information
We process your personal information for the purposes and in the manner described in this Privacy Policy. We use your personal information only when necessary and ensure that all processing activities comply with the Nigeria Data Protection Act (NDPA) and other applicable laws and regulations.
The primary purposes for which we use your personal information include the following:
5.1 Provision and Administration of Our Services
We process your personal information for the purpose of providing and administering our Services, including loan-related operations and account management.
i. Processing your account registration, loan applications, credit assessments, loan disbursement, and repayment transactions.
ii. Verifying your identity, contact details, and the authenticity of information and documents submitted.
iii. Generating and managing your loan records, account statements, and service-related notifications.
iv. Providing customer support and responding to your inquiries, complaints, or service requests.
5.2 Credit Assessment, Risk Management, and Fraud Prevention
We process your personal information to conduct credit assessment, risk management, and fraud prevention activities, which are essential for the provision of our financial Services.
Such processing may include:
i. Assessing your creditworthiness, repayment capacity, and financial behavior to support lending decisions;
ii. Developing, maintaining, and improving risk assessment models and credit evaluation methodologies;
iii. Verifying the accuracy, completeness, and consistency of the information you provide;
iv. Detecting, preventing, and investigating fraudulent, suspicious, or unauthorized activities;
v. Monitoring account activity and transaction patterns to identify potential risks and ensure service security.
Where applicable, we may use automated decision-making technologies, including profiling, for the purpose of evaluating credit risk and determining eligibility for our Services.
All such processing is conducted in a lawful, fair, and transparent manner, and is strictly limited to what is necessary for the purposes described above, in accordance with applicable data protection and financial regulations.
5.3 Necessary Communications with You
We may use your personal information to send you important service-related communications, including:
i. Repayment reminders, interest rate adjustments, account security alerts, and policy updates;
ii. Responses to your inquiries or feedback submitted through the email;
iii. Product updates, where you have provided explicit consent;
5.4 Compliance with Legal and Regulatory Obligations
We process your personal information as required to comply with applicable legal and regulatory obligations, including:
i. Submitting reports or information to regulatory authorities, tax authorities, or other competent bodies, including anti-money laundering and counter-terrorist financing requirements;
ii. Responding to court orders, government requests, or lawful law enforcement inquiries;
iii. Retaining loan records and identity verification materials in accordance with applicable legal retention requirements;
iv. Supporting audits, compliance reviews, and dispute resolution procedures.
5.5 Other Uses Compatible with the Above Purposes
We may process your personal information for other purposes that are compatible with the original purposes described above, including:
i. Ensuring service continuity in the event of mergers, acquisitions, asset transfers, or business restructurings;
ii. Protecting the lawful rights and interests of us, you, or third parties, including debt recovery and handling legal claims.
5.6 Key Commitments and Your Rights
We will not use your personal information for purposes not specified in this Policy. If new purposes arise, we will notify you in advance and obtain your consent where required.
We regularly review our data processing activities to ensure compliance with the principles of data minimization and purpose limitation.
5.7 Legal Basis
Our processing activities are based on one or more of the following legal grounds:
i. Performance of a contract with you, as necessary for the provision of loan services;
ii. Compliance with legal obligations, including regulatory reporting and anti-money laundering requirements;
iii. Our legitimate interests, such as security protection, service improvement, and risk management, provided that such interests do not override your fundamental rights and freedoms;
iv. Your consent, for marketing communications or other optional purposes.
6. How We Share Your Personal Information
We treat your personal information with strict confidentiality and only share it under limited circumstances, where necessary for the provision of the Services, compliance with legal obligations, or protection of legitimate interests, and always subject to appropriate safeguards.
We do not sell your personal information to any third party, nor do we disclose it for purposes unrelated to those set out in this Privacy Policy.
6.1 Sharing with Service Providers
We may share your personal information with third-party service providers who act on our behalf to support the operation and delivery of the Services, including but not limited to:
i. Identity verification service providers
ii. Payment processing and fund disbursement providers
iii. Cloud storage and infrastructure providers
iv. Customer support and communication service providers
v. Fraud detection and risk control service providers
Such service providers are contractually required to:
i. Process personal information solely in accordance with our documented instructions;
ii. Maintain strict confidentiality and implement appropriate technical and organizational security measures;
iii. Use personal information only to the extent necessary to provide the agreed services;
iv. Comply with applicable data protection laws and regulations.
We conduct due diligence and ongoing monitoring to ensure that such providers meet our data protection and security standards.
6.2 Sharing Within Our Corporate Group
We may share personal information with affiliated entities within the Pure Cash group for legitimate business purposes, including:
i. Provision of integrated services
ii. Risk management and internal control
iii. Internal audit and compliance management
All intra-group data sharing is subject to internal data protection policies and appropriate safeguards designed to ensure a consistent level of protection.
6.3 Legal and Regulatory Disclosures
We may disclose your personal information where required by law or where we reasonably determine that such disclosure is necessary, including to:
i. Regulatory authorities, tax authorities, anti-money laundering (AML) bodies, and other competent government agencies
ii. Courts, tribunals, or law enforcement authorities in response to lawful requests, court orders, or investigations
iii. External auditors, legal advisers, or other professional consultants for compliance, audit, or dispute resolution purposes
Any such disclosure shall be limited to the minimum amount of personal information necessary to fulfill the relevant legal requirement.
6.4 Business Transfers
In the event of a merger, acquisition, restructuring, asset transfer, insolvency, or similar corporate transaction, your personal information may be transferred as part of the relevant business assets.
In such cases:
i. The receiving entity shall be required to process your personal information in a manner consistent with this Privacy Policy;
ii. Appropriate safeguards shall be implemented to ensure continued protection of your data;
iii. Where required by applicable law, you will be notified in advance of such transfer.
6.5 Protection of Legal Rights and Safety
We may disclose personal information where necessary to:
i. Protect our legal rights, interests, or property
ii. Enforce our terms of service, including debt recovery or contractual obligations
iii. Detect, prevent, or address fraud, security incidents, or unlawful activities
iv. Protect the safety or rights of users or the public
Such disclosures shall be made only where necessary and proportionate.
6.6 Your Consent and Additional Safeguards
Except as described in this Policy, we will not disclose your personal information to third parties without your prior consent.
We require all recipients of personal information to:
i. Implement appropriate technical and organizational security measures
ii. Process personal information solely for authorized purposes
iii. Comply with applicable data protection laws and regulations
7. Security and Data Protection
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, misuse, alteration, disclosure, or destruction. Such measures are designed in accordance with applicable laws, including the Nigeria Data Protection Act (NDPA), and generally accepted industry standards, taking into account the nature, scope, and sensitivity of the personal information processed.
7.1 Security Measures
Our security measures include, but are not limited to:
i. Encryption of personal information during transmission and, where appropriate, at rest;
ii. Access control mechanisms to prevent unauthorized access to systems and data;
iii. Secure system architecture and continuous monitoring to detect and prevent unauthorized intrusion or misuse;
iv. Periodic review, testing, and updating of security controls and practices.
7.2 Access Control and Confidentiality
Access to personal information is strictly limited to authorized personnel who require such access for legitimate business purposes.
All such personnel are subject to:
i. Confidentiality obligations;
ii. Internal data protection policies and procedures;
iii. Restrictions on the use, processing, and disclosure of personal information strictly in accordance with our instructions and applicable laws.
7.3 Data Breach Management
We maintain internal policies and procedures to detect, respond to, and mitigate potential data security incidents.
In the event of a suspected or confirmed personal data breach:
i. We will promptly assess the nature, scope, and potential impact of the incident;
ii. We will take appropriate remedial actions to contain, mitigate, and, where possible, remediate any adverse effects;
iii. Where required by applicable laws and regulations, we will notify affected users and relevant regulatory authorities within the prescribed timeframes.
7.4 Security Limitations and User Responsibilities
We implement appropriate technical and organizational measures to protect your personal information. However, security risks may still arise in certain circumstances beyond our reasonable control.
You are responsible for maintaining the confidentiality of your account credentials and for taking reasonable precautions to protect your personal information, including securing your device and preventing unauthorized access to your account.
8. How We Store Your Personal Data and Retention Period
We store and process your personal data for as long as necessary to fulfill the purposes for which it was collected, including the provision of our Services and compliance with applicable legal, regulatory, and operational requirements.
Your personal data is stored using secure electronic systems and, where necessary, secure physical records. We implement appropriate technical and organizational measures designed to protect your personal data against loss, misuse, unauthorized access, alteration, or disclosure.
Where you request cessation of processing of your personal data, we may, where permitted by applicable law, suspend or terminate the relevant Services within a reasonable period or immediately where required.
8.1 Data Retention Period
We may retain your personal data beyond the duration of your relationship with us where:
i. Retention is required or permitted by applicable laws or regulations;
ii. The data is reasonably necessary for legitimate business, operational, or risk management purposes;
iii. Retention is required for the performance or enforcement of a contract between you and us;
iv. You have provided consent for continued retention;
v. The data is retained for statistical, analytical, or research purposes, subject to appropriate safeguards, including anonymization or pseudonymization where applicable.
8.2 Data Deletion and Anonymization
Where personal data is no longer required for the purposes for which it was collected, we will either:
i. Securely delete or destroy the data; or
ii. Irreversibly anonymize the data so that it can no longer be linked to you.
8.3 Regulatory and Legal Retention Requirements
Notwithstanding the above, we may be required to retain certain personal data for extended periods under applicable laws and regulations, including but not limited to anti-money laundering (AML), counter-terrorism financing (CTF), customer due diligence, and financial record-keeping obligations.
9. Your Rights in Relation to Your Personal Data
Under the Nigeria Data Protection Act (NDPA) and other applicable data protection laws, you have the following rights in relation to your personal data. We are committed to facilitating the exercise of these rights in accordance with applicable legal requirements.
9.1 Right to Be Informed and Right of Access
You have the right to be informed about whether we process your personal data and to obtain information regarding such processing. You may also request access to a copy of the personal data we hold about you, subject to applicable legal limitations.
9.2 Right to Rectification
You have the right to request correction or completion of inaccurate, incomplete, or outdated personal data. We will take reasonable steps to verify and update such data and, where appropriate, notify relevant third parties.
9.3 Right to Erasure
You may request deletion of your personal data where legally permissible, including where:
i. The data is no longer necessary for the purposes for which it was collected;
ii. You withdraw consent and there is no other legal basis for processing;
iii. The data has been unlawfully processed.
We may, however, retain certain information where required by applicable laws, including AML, regulatory, or financial record-keeping obligations.
9.4 Right to Restriction of Processing
You may request restriction of processing where:
i. You contest the accuracy of the data;
ii. Processing is unlawful and you request restriction instead of deletion;
iii. We no longer require the data but you need it for legal claims;
iv. You have objected to processing pending verification of legitimate grounds.
9.5 Right to Object
You have the right to object to processing based on our legitimate interests. You also have an absolute right to object to the processing of your personal data for direct marketing purposes.
9.6 Right to Withdraw Consent
Where processing is based on your consent, you may withdraw such consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal and may not affect the provision of core Services where processing is based on contract or legal obligation.
9.7 Right to Data Portability
Where technically feasible and applicable, you may request to receive your personal data in a structured, commonly used, and machine-readable format, or request transmission to another service provider where appropriate.
9.8 Important Limitations
The exercise of certain rights may be limited where necessary to comply with legal obligations, including AML, CTF, regulatory reporting, or other statutory requirements. Any such limitation will be communicated to you where applicable.
You are responsible for ensuring that the personal data you provide is accurate and up to date to enable us to properly exercise your rights and provide our Services.
10. Protection of Minors
Pure Cash's services are intended only for individuals who are at least 18 years old and have full legal capacity. We do not knowingly collect, process, or store personal information of individuals under the age of 18 ("Minors").
If you are under 18 years old, please stop registering, applying for, or using our website, app, or any services immediately.
If we discover or suspect that an account belongs to a minor, we reserve the right to immediately suspend or terminate the account, refuse to provide services, and delete any personal information we hold about the minor (except as required by law).
Parents or guardians who become aware that a minor under their care has used our services without authorization should promptly contact us using the methods provided in Section 11. We will take appropriate steps to delete the related information and terminate the service as soon as possible.
We do not intentionally send marketing communications to minors, nor do we knowingly provide loans or other financial services to individuals under 18 years old.
By registering an account, submitting an application, or using our services, you confirm that you are at least 18 years old and have full legal capacity.
This policy reflects our commitment to comply with the Nigeria Data Protection Act (NDPA) and other applicable laws and regulations protecting the privacy of minors.
11. How to contact us, support and inquiries
Nigeria Data Protection Act of the Federal Republic of Nigeria, the following will apply: If you have any queries about the content of this Privacy Policy, or wish to inform us of a change or correction to your personal information, would like to exercise any of those rights or would like to raise a complaint or comment, please contact us at purecashgp@ddigitaldelight.com.
It is important that the personal data we hold about you is accurate and current. Please
keep us informed if your personal data changes during your interaction with us.