Introduction
We understand that privacy is a top priority for you. We encourage you to read this Privacy Policy to gain a clear understanding of the information we collect, how we use it, and the choices available to you.
This Privacy Policy applies to the information we collect through our business activities. This includes data collected via 2SE MICRO-CREDIT ENTERPRISE’s website, online forums, marketing initiatives, research, and other online or offline programs operated by or on behalf of 2SE CREDITBOX. We refer to these products, services, and programs collectively as "Services." By using our Services, you agree to the terms of this Privacy Policy, including our processes for collecting, transferring, and storing your information.
In this Privacy Policy, references to "2SE CREDITBOX," "we," and similar terms refer to 2SE MICRO-CREDIT ENTERPRISE and its affiliated entities under the same ownership and control. Your information is managed by one of these entities.
2SE CREDITBOX is the name of the app developed and operated by 2SE MICRO-CREDIT ENTERPRISE. 2SE MICRO-CREDIT ENTERPRISE is a legally registered limited liability company in Ghana with the following details:
- Registration number: BN143633427
- Registered address: 8 Aladjeitey Road Adenta Down Curve, Accra, Ghana
The Information We Collect
The type of information we collect depends on how you use our services, the services you interact with, and the information you provide to us.
We collect information in three primary ways: (1) information you choose to provide to us, (2) information we collect automatically through technology when you use our services, and (3) information we gather from other sources.
Information You Choose to Provide to Us
When you use our services, you may choose to provide certain personal details.For example, we collect information directly from you when you make a purchase, create or use a 2SE CREDITBOX account, your whatsapp account number, register for account, post reviews, photos of your information (such as your ID photos, your vote card photos), and other information including your submited your base information, your working information, your contacts information.
Common categories of information we collect directly from you include:
- Contact and account information: This includes your phone number, your name, ID number, sex, age, address, phone number, email address, date of birth, and login credentials (such as your 2SE CREDITBOX account details).
- Financial information: Such as your bank card details or your ewallet numbers.
- Customer service interaction data: This includes any information submitted via online forms or emails, as well as summaries or recordings (voice or video) of interactions with customer service.
- Your contacts data: This includes contact information that you voluntarily submit, including name, contact information, location, etc.
- Survey and prize draw information: Includes details like your interests, preferences, demographic data (e.g., gender), photos, videos, and other information required for event participation, prize redemption, or incentive programs.
Information We Collect Automatically Through Technology
1. Device Information
To enhance your user experience and ensure the security of our services, 2SE CREDITBOX collects basic information about your device. This includes, but is not limited to, device model, operating system version, unique device identifiers (e.g., IMEI), IP address, etc. We use this information solely to improve app performance, diagnose issues, prevent fraud, and enhance service quality. We do not share this data with third parties unless required by law or necessary for service delivery.
2. Coarse Location
In accordance with applicable regulations, 2SE CREDITBOX collects your approximate geographical location. This is essential to confirm that you are in an area where our service is available and to ensure compliance with local laws and our terms of service. Rest assured, we do not track or record your precise location, nor do we use this data for any other purposes. We only request this permission when necessary and with the least impact on your privacy.
3. SMS Access
To verify your identity and assess your credit status, 2SE CREDITBOX may access your SMS history. This is crucial for account security and the accuracy of our credit assessments, particularly for messages from financial institutions or service providers. All accessed text messages are handled with strict confidentiality and used only for internal purposes. We will never share any of your text messages with third parties without your explicit consent.
4. Camera Access
To facilitate the submission of required identification or documents, 2SE CREDITBOX may request access to your device's camera. This allows you to take photos or scan documents directly within the app. You are in full control of this permission and can choose whether or not to grant access to the camera. Please note that this feature is only used when necessary, and all image data is processed locally on your device—nothing is uploaded to our servers unless required by law or for service purposes.
5. Application List
Access to your list of installed applications helps us identify potential security risks, such as malware, that may affect the functionality of our services. By understanding your device environment, we can enhance your security and provide a better, more personalized experience. We do not link your app list to any other personal data or use it for marketing or unrelated purposes.
6. Google AD ID
For a personalized advertising experience, 2SE CREDITBOX uses your Google AD ID. This allows us to show you more relevant ads while respecting your privacy. We do not associate this ID with any personally identifiable information. If you prefer not to receive personalized ads, you can reset your Google AD ID at any time through your device settings. For a detailed description of google AD ID, see the section 'Online Analytics and Advertising'.
Information We Collect from Other Sources
We may receive information about you from third-party sources to supplement the information we have on file.This may include business partners, researchers, marketers, social networking services, and other entities.
If you access our services through third-party websites, apps, or social media platforms (e.g., Facebook), we may receive details about you (such as your name, username, phone number, or content you post) from these platforms, depending on their privacy practices and your settings.Please note that 2SE CREDITBOX is not responsible for the practices or content of third-party websites, apps, or social media platforms.We recommend reviewing the privacy and security policies of any third-party services you use.
De-Identified Data
We may de-identify the information we collect in a way that it no longer reasonably identifies you or your device.We may also collect de-identified information.The use and disclosure of de-identified data are not restricted by this Privacy Policy.As such, we may use and disclose such data for any purpose without limitations.
Online Analytics and Advertising
Online Analytics
We may use third-party analytics services (such as Apple's Advertising Identifiers, IDFA) to gather data on how users interact with our services. These service providers may use their own cookies, pixel tags, and similar technologies to collect information that allows them to track users over extended periods and across different services. These analytics help us understand how users access and use our services, which in turn allows us to improve user experience.
If you prefer not to have your usage data collected by Apple's advertising identifier, you can opt out by adjusting the settings in your web browser. Alternatively, you can disable this feature directly on your phone by going to **Settings** > **2SE CREDITBOX** > **AD Identifiers** > **Off** (or a similar setting depending on your device).
Online Advertising
At 2SE CREDITBOX, we aim to offer relevant and valuable content through our online advertising. While we do not serve third-party ads directly within our services, we collaborate with online analytics and advertising partners to display 2SE CREDITBOX ads across third-party websites. These partnerships help us personalize and enhance the ads and messaging you receive about our services.
Our advertising partners may also use cookies, pixel tags, and similar technologies across various online platforms, including ours. These technologies are designed to collect data on your interactions with these services and provide more targeted advertising. For example, they may use the information collected through these cookies to identify 2SE CREDITBOX products or services that may be of interest to you. They may also track your devices so that relevant 2SE CREDITBOX ads are displayed to you both on our services and other platforms.
Furthermore, we may share basic information we collect, such as email addresses, with our advertising partners. These partners may match this data with cookies, mobile advertising identifiers, or other proprietary identifiers (in a de-identified form) to deliver more relevant ads when you visit other online services.
How We Use Your Information
We use the information we collect in the following ways:
1. To Provide the Services You Request: This includes completing purchases, delivering subscriptions, offering customer support, or integrating with your chosen streaming services.
2. To Communicate with You: We may use your information to keep you informed about purchases, shipments, product/software updates, and changes to our terms, conditions, and policies.
3. For Marketing and Advertising: Your information may be used to send you the latest product announcements, promotions, and information about upcoming events.
4. To Personalize Your Experience: We customize services by providing relevant content and recommendations, managing your product wish list, and personalizing your interactions with our services.
5. To Improve Our Services: We analyze data for error detection and reporting, conducting research, improving accuracy, enhancing usability, understanding user behavior, and testing new products and features.
6. For Business Operations: We may use your information to manage your account for security purposes, fraud prevention, and legal compliance, including detecting security incidents and preventing illegal or fraudulent activities.
7. To Identify Users Across Touchpoints: We may use the information we collect (such as usernames, IP addresses, and device identifiers) to identify you across various 2SE CREDITBOX services, personal devices (smartphones, tablets), and browsers (like Safari and Chrome).This helps us create a unified user profile and deliver a seamless, personalized experience across different platforms.
8. For Other Purposes Requiring Your Consent: We may use your information for specific purposes for which we have informed you and obtained your consent, in compliance with applicable laws.
9. To Comply with Legal Process and Protect Our Rights: We may use and disclose your information when necessary to:
- Comply with legal processes (such as subpoenas or court orders).
- Enforce our terms of service, Privacy Policy, or contracts with you (including investigating potential violations).
- Respond to claims that any content violates third-party rights.
- Protect the rights, property, or personal safety of 2SE CREDITBOX or others.
Legal Basis for Processing Your Information
Depending on the jurisdiction, we may need to inform you of the legal basis for processing your data.The legal bases on which we rely to process your information include:
- Contractual Necessity: We process your information to fulfill our obligations under contracts or commitments with you, such as providing a service you’ve requested or complying with our website’s terms of service.
- Legal Obligations: We may use your information to meet statutory duties and legal obligations, such as tracking purchases for tax and audit purposes or ensuring security in our services.
- Consent: In some cases, we process your data based on your consent for specific purposes.
- Vital Interests: We may process your information to protect the life, health, or property of a person in an emergency situation.
- Publicly Available Information: If you have made your information public or it has been made public legally, we will use it in accordance with applicable laws.
Combining Information
For the purposes outlined in this Privacy Policy, we may combine the information collected through our services with information received from other sources, both online and offline. We will handle this combined information in accordance with the terms of this Privacy Policy.
How We Disclose Your Information
2SE CREDITBOX may disclose your information in the following ways:
1. Within Associated Entities
We may share your information within 2SE CREDITBOX’s affiliated companies to provide services, operate our business, and enhance your customer experience.
2. To Service Providers
We use third-party service providers to help us deliver services and manage our business. These providers may be given access to your information or may be required to process it. They assist us with various tasks, including customer service, payment processing, marketing, product design and development, data storage, security, fraud prevention, research, and legal services. These service providers are only authorized to access and use your information as needed to provide services to 2SE CREDITBOX or to comply with applicable legal requirements.
3. To Online Advertising Partners
As outlined in the "Online Advertising" section and further explained in our Cookie Statement, we may share certain details about you with our online advertising partners. This is to assist with advertising, targeting, and measurement activities.
4. To Connected Third-Party Platforms, Websites, Applications, and Services
When you initiate a connection to a third-party platform, website, application, or service through our services, we may disclose your information to facilitate the delivery of third-party content or services. By using these third-party services, you agree to their respective policies and terms. We encourage you to review the privacy and security policies of these third parties.
5. To Protect 2SE CREDITBOX and Others
If required by law, or if we believe that disclosure is necessary in good faith to:
- Comply with legal processes (such as subpoenas or court orders),
- Enforce our terms of service, Privacy Policy, or other agreements (including investigating potential violations),
- Respond to allegations of content infringement,
- Protect the rights, property, or personal safety of 2SE CREDITBOX or others,
we may disclose the information we have collected about you.
6. Business Transfers
As our business evolves, we may acquire, merge with, or partner with other companies. In these cases, your information may be included in the transferred assets. If 2SE CREDITBOX’s assets are sold, either partially or entirely, to a third party, your information may be shared or transferred as part of the transaction. However, such sharing will always be limited to what is necessary for the transaction, will not exceed the purposes and methods for processing your information to which you initially agreed, and will not be done without proper legal consent.
Children's Privacy
Our services are primarily designed for adults. As parental consent is required to collect data from children under the age of consent, if we become aware that we have unintentionally collected data from a child without obtaining valid parental consent, we will take prompt and reasonable steps to delete such data.
Security and Retention of Your Information
Security of Your Information
We are dedicated to safeguarding your information. We employ a range of security measures at technical, physical, and organizational levels to protect against unauthorized access, modification, disclosure, or destruction of your data. However, no security system is completely foolproof, and we cannot guarantee the absolute security of your information.
When using your 2SE CREDITBOX account, we recommend selecting a strong password and keeping it confidential. If you suspect unauthorized access to your account, please notify us immediately.
We consistently monitor our services for potential vulnerabilities and security risks. If you have any concerns or questions regarding the security of our services, please reach out to us as outlined in the "Contact Information" section below, and we will address your concerns promptly and effectively.
Retention of Your Information
As outlined in this Privacy Policy, we retain information for varying durations depending on the purpose for which it was collected and used. For instance, in compliance with the Status of Registration of Fintech/Digital Companies with the Federal Competition and Consumer Protection Commission (FCCPC) under the Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending 2022, we are required to store transaction-related data for at least six months from the transaction date.
To comply with the legal and regulatory requirements in Nigeria, Egypt, and Ghana regarding web services, we will retain web user data for a minimum of six months after collection. If the information is no longer needed for the specified purposes, we will either delete or anonymize it, unless a longer retention period is mandated by applicable law.
For technical or operational reasons, there may be instances where we are unable to fully delete or anonymize your information. In such cases, we will take reasonable steps to prevent further processing of the data.
Your Control and Choices
When we collect, use, and disclose your information, you have certain rights and choices. Your legal rights to exercise control over your information may vary depending on the laws of your jurisdiction.
You can make the following requests by completing our online application form or contacting us (please refer to the "Contact Information" section below for details):
- Access or copy your information
- Correct or amend your information
- Delete your account
- Transfer your information to third parties
- Restrict or object to the use of your information for certain purposes
- Clarify the purposes for which we process your information
If you have given us consent to use your information for a specific purpose, you may also request to revoke that consent.
Before responding to your request, we may ask you to provide additional information to help us verify your identity. We will review your request and respond within the timeframes set by applicable law. However, please note that some information may not be subject to such requests.
You also have the option to control your information in the following ways:
- Limit the information you provide: When interacting with us, you can choose to limit the information you share. However, this may affect your ability to access certain services, and we may not be able to fulfill your requests fully.
- Close your 2SE CREDITBOX account: To close your account, please complete our online application form or contact us (refer to the "Contact Information" section below). Account cancellation is not automatic. Once we verify your phone number, we will process your request within 15 days unless otherwise informed.
- Adjust location collection settings: For the 2SE CREDITBOX mobile app, you can disable location tracking on your device. The steps to do so may vary by device; please refer to your device settings or contact your device manufacturer for further assistance.
Information on Cross-Border Data Sharing
As a global organization, we may transfer, store, and/or process your information outside of your home country to provide services, fulfill legal obligations, or for purposes outlined in our Privacy Policy (see section "How We Use Your Information" above).
By acknowledging our Privacy Policy, you consent to the transfer of your information to the following countries outside Nigeria:
- Recipient: 2SE MICRO-CREDIT ENTERPRISE
- Recipient countries: Nigeria, Ghana, Egypt
- Types of personal information:
- Contact and account information: Name, address, phone number, email address, WhatsApp account.
- Customer service interaction and transaction information: Information submitted via email, summaries of interactions with customer service, order/transaction history, repairs, and returns.
- Purpose of data transfer:
1. To provide the requested services to customers.
2. To offer customer support and troubleshooting.
3. To process data subject claims.
4. To communicate with customers, including updates on shipments, and changes to terms, conditions, and policies.
5. For business and security operations, including account maintenance.
6. For security, fraud prevention, and legal compliance, such as detecting security incidents, preventing fraudulent activities, and handling related inquiries and complaints.
- Recipient contact information:service@2semicrocredit.club
Whenever your data is transferred, stored, or processed, we will take reasonable steps to protect it in line with this Privacy Policy and applicable laws. These measures may include implementing standard contractual terms or other legally recognized methods for protecting your data during transfer.
If you are concerned or dissatisfied with our data processing activities, we encourage you to first contact us directly to address your issues. However, if necessary, you may lodge a complaint with your local data protection authority. Alternatively, if you believe your rights have been violated, you may seek legal recourse through the appropriate court in your jurisdiction.
Changes to Our Privacy Policy
We may update or modify this Privacy Policy from time to time to reflect changes in applicable laws, data collection practices, service features, or technological advancements. We encourage you to periodically review this Privacy Policy and check the "Effective Date" at the beginning of the document to see if any changes have been made since your last review. By continuing to use our services, you acknowledge that you have read, understood, and accepted the most recent version of this Privacy Policy.
If we make significant changes to this policy, we will notify you through our services or other means, as required by applicable law, to provide you with an opportunity to review the changes before they become effective.
Contact Information
If you have any questions, concerns, or complaints about this Privacy Policy, or if you would like to contact us, please email us at:service@2semicrocredit.club
Alternatively, you can visit the "Contact Us" page for additional contact information for 2SE CREDITBOX.