Privacy Policy

Updated in September 2024

Introduction

At Lily Fintech Ltd. (“we,” “our,” or “us”), we are dedicated to protecting your privacy and ensuring the confidentiality of your personal data. We adhere to the Nigerian Data Protection Act 2023 (NDPA) and other relevant laws, including guidelines from the Securities and Exchange Commission (SEC).

This Privacy Policy outlines how we collect, use, share, and protect your personal data when you engage with us through our website, mobile applications, or other services. It also explains your rights and how to exercise them.​

Scope

This Privacy Policy applies to all personal data collected, processed, and stored by Lily Fintech Ltd. as part of our operations in the capital markets and financial services sector, including any interaction via our website, mobile applications, and customer service channels.

Data Collection

We collect personal data to provide and improve our services. Based on your interactions with us, we may collect the following types of data:

  • Personal Identification Information: Full name, date of birth, gender, nationality, government-issued identifiers (e.g., National Identity Number, BVN, passport number).

  • Contact Information: Phone numbers, email addresses, and physical addresses.

  • Financial Information: Bank account details, transaction history, and financial data such as:
    • Investment amounts
    • Types of transactions (e.g., purchases, sales, transfers)
    • Investment preferences and goals
    • Account balances and statements

  • Employment Information: Occupation, employer details, and other work-related information (if applicable).

  • KYC/AML Data: Information required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance, including identity verification and risk assessment data.

  • Technical Information: IP addresses, device identifiers, browser type, operating system, and data collected through cookies and similar technologies, including location data for optimizing our services.

  • Behavioural Data: Details on how you engage with our services, such as:
    • Clicking links in our communications
    • Interaction with customer support (e.g., chat transcripts, call recordings)
    • Website and application usage (e.g., pages visited, time spent)

Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Consent: When you explicitly agree to certain processing activities, such as receiving marketing communications.

  • Contract: To fulfill our contractual obligations to you or take steps at your request before entering a contract.

  • Legal Obligation: To comply with legal, regulatory, and compliance requirements, including SEC regulations and the NDPA.

  • Legitimate Interests: When necessary for our legitimate interests, including:
    • Service Improvement: Analyzing user behavior to enhance offerings.
    • Customer Support: Refining support services based on interaction data.
    • Targeted Marketing: Personalizing marketing based on user preferences.
    • Fraud Prevention: Detecting and preventing fraudulent activity.

Use of Personal Data

We use your personal data for the following purposes:

  • Providing Services: Facilitating financial transactions, managing accounts, providing investment advice, and delivering financial services.

  • Regulatory Compliance: Ensuring compliance with NDPA and SEC regulations.

  • Customer Support: Responding to inquiries and providing technical assistance.

  • Marketing & Communication: With your consent, sending promotions, service updates, newsletters, and event information. For instance:
    • Sending targeted marketing emails based on your investment preferences.
    • Providing personalized recommendations based on transaction history.

  • Risk Management & Fraud Prevention: Detecting and preventing fraudulent or illegal activities.

  • Data Analytics: Analyzing service usage patterns to enhance the user experience.

Data Sharing and Disclosure

We may share your personal data with:

  • Regulatory Authorities: As required by law or regulation.

  • Service Providers: Third-party service providers who help us, such as:
    • Payment processors (e.g., Paystack)
    • Analytics providers (e.g., Google Analytics)
    • Customer support tools (e.g., Zoho Desk)

  • Affiliates & Partners: For business continuity, ensuring they comply with our data protection standards.

  • Legal & Enforcement Bodies: When necessary to comply with legal obligations or protect our rights.

International Data Transfers

If your personal data is transferred outside Nigeria, we will ensure appropriate safeguards, such as legally binding agreements or Standard Contractual Clauses (SCCs), to comply with international data protection standards, such as those in the GDPR.

Implications for Users: Data processed in other countries may be subject to different laws. We take measures to ensure your rights are protected under applicable laws.

Data Retention

We retain your personal data only as long as necessary for the purposes for which it was collected or as required by law. Common retention periods include:

  • Personal Identification Data: Retained for the duration of your relationship with us and a specified period thereafter, typically 6 years.

  • Financial Data: Retained for at least 5 years in compliance with regulatory requirements.

  • Transaction Data: Retained for a minimum of 5 years from the last transaction date.

Once no longer needed, your data will be securely deleted or anonymized in compliance with legal requirements.

Data Security

We use industry-standard technical and organizational measures to protect your personal data. This includes encryption and secure access controls. However, common threats like phishing, malware, and data breaches exist, so we recommend you:

  • Use strong, unique passwords for your accounts.
  • Be cautious of suspicious emails and links.
  • Keep your software and devices up to date.

Your Rights

Under the NDPA, you have the right to:

  • Access: Request a copy of your personal data.
  • Rectification: Correct inaccurate or incomplete personal data.
  • Erasure: Request the deletion of your personal data, subject to legal exceptions.
  • Restriction: Request restricted processing of your personal data in certain cases.
  • Data Portability: Receive your personal data in a structured, commonly used format.
  • Objection: Object to the processing of your personal data, especially for legitimate interests or direct marketing.

To exercise your rights:

  • Submit a request by contacting us (details in Section 13).
  • Provide your name, contact details, and specifics of your request.
  • We may verify your identity before processing your request.
  • We aim to respond within 30 days.

Cookies and Tracking Technologies

We use cookies and similar technologies to improve your browsing experience and personalize our services. We use:

  • Essential Cookies: Necessary for website functionality.
  • Performance Cookies: To enhance performance based on user behavior.
  • Functional Cookies: To enable additional features and personalization.

You can adjust your cookie preferences via your browser settings. For more information, please refer to our Cookies Policy.

Changes to this Policy

We may update this Privacy Policy to reflect changes in legal, regulatory, or operational requirements. When significant changes occur, we will notify you at least 30 days in advance through:

  • Email Notifications: Sent to your registered email.
  • Website Banners: Displayed on our website.
  • In-App Notifications: Shown within our mobile apps.

Contact Us

For questions or concerns regarding this Privacy Policy, please contact us:

Lily Fintech Ltd.
3 Birrel Avenue, Yaba, Lagos, Nigeria
Phone: +234-123-4567
Email: feedback@lily.com.ng

Data Protection Officer (DPO):
Warren Oluwasanya
Email: dpo@lily.com.ng

Feedback

We welcome feedback on our Privacy Policy and services. Contact us with:

  • Service Satisfaction: Your experience with our services.
  • Data Usage Concerns: Concerns about how your data is handled.
  • Suggestions for Improvement: Ways we can improve our services or policies.

Accessibility

This Privacy Policy is available in accessible formats such as:

  • Audio format

If you need assistance, please contact us.

Policy Review Frequency

We review this Privacy Policy annually, or more frequently in response to regulatory or business changes. Significant changes will be communicated via:

  • Email Notifications
  • Website Banners
  • In-App Notifications
  • Social Media

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LILY is a digital product of MagnaCap Ltd, a company duly licensed by the Securities and Exchange Commission (SEC). LILY and its logo are registered trademarks. LILY is safe and secure and in compliance with NDPR audit. Payments on the LILY App are processed via a CBN licensed and PCI DSS certified payment platform with bank level security to ensure client transactions and financial information are always kept safe. Our users’ financial assets are held with a licensed custodian Access Investors Services Nominees Limited, for safekeeping.

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