Privacy Policy

This privacy policy (Policy) together with our Terms of Use and Account Agreement and any additional terms of use applies to your use of:

1. MEMCOS is a mobile application software (App) built by CWG PLC and available on MTN Coop site OR hosted on the Google Play Store (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

2. Any of the services accessible through the App (Services) or those available on the App Site or other sites of ours or other third-party Sites (Service Sites).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading the App, you confirm that you have read, understood and accepted the terms of this Policy set out hereunder. You also consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy.

A. Information we may collect from you

We may collect and process the following data about you.

i. Information you give us about you (Submitted information):

This may include information:

• • provided by filling in forms when visiting our sites or on our App;

• • provided by corresponding with us (for example, by e-mail or chat);

• • provided by downloading or signing up on the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App's social media functions, entering a competition, promotion or survey, and reporting a problem with the App, our Services, our App Site or any of Our Service Sites.

This information may include your name, address, e-mail address and phone number, the Device's phone number, age, username, password and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description and photograph.

ii. Information we collect about you and your device.

Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:

• • Technical information, including the type of mobile device you use, unique device identifiers (for example, your Device's IMEI or serial number), information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information);

• • Information stored on your Device, including contact lists, call logs, SMS logs, social media accounts, other financial applications, photos, videos or other digital content (Content Information);

• • Data from your use of any other third-party application on the Device or the Service Sites; and

• • Details of your use of any of our Apps or your visits to any of Our Service Sites; including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information).

iii. Location information.

We also use GPS technology OR other location services to determine your current location. You can withdraw your consent to our collection, processing or use of this information at any time by logging out and uninstalling the App from your Device.

iv. Information we receive from other sources (Third Party Information).

Due to the nature of the Services which we provide, we are required to work with a number of third parties (including credit reference agencies and mobile network providers) and we may receive information about you from them.

v. Unique application numbers.

When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

B. Tracking and cookies

We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site, or Service Sites. This helps us to provide you with a good experience when you use the App or browse any of the Service Sites and also allows us to improve the App and Our Service Sites.

C. Uses made of the information

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.

Information collected by us shall be used for the purpose of determining whether or not to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan.

Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied for a loan on any given day).

D. Disclosure of your information

We may disclose some or all of the data we collect from you when you download or use the App to credit reference bureaus.

We may disclose your personal information to any member of our group, which means our subsidiaries, affiliates, or holding company and its subsidiaries.

We may disclose your personal information to third parties:

• • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

• • if CWG or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

• • if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or

• • in order to: enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

E. Where We store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside your country of origin or residence (as applicable). It may also be processed by staff operating outside your country of origin or residence (as applicable), who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests on the Service Sites. By submitting your personal data, you agree to the collection, transfer, storing or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this privacy Policy.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure, however, we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

F. Your rights

We will use your data for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at support@mtncoop.com

G. Changes to privacy policy

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Service Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. In any event, by continuing to use the App or any Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.

Use of Data

The mobile application uses the collected data for various purposes:

• • To comply with applicable laws, regulations, legal processes or government request including but not limited to Know Your Customer Principles, Customer Due Diligence, Anti-Money Laundering and Anti-Terrorism Financing

• • To provide and maintain the Service

• • To notify you about changes to the Service

• • To allow you to participate in interactive features of our Service when you choose to do so

• • To provide customer care and support

• • To provide analysis or valuable information so that we can improve the Service

• • To monitor the usage of the Service

• • To use your Personal Data for operational, marketing and other promotional purposes.

• • To detect, prevent and address technical issues

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your town, city, local government area, state, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Nigeria and choose to provide information to us, please note that we transfer the data, including Personal Data, to Nigeria and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Personal Data

We may disclose your Personal Data in the good faith belief that such action is necessary to:

• • Comply with a legal obligation

• • Protect and defend our rights or property

• • Prevent or investigate possible wrongdoing in connection with the Service

• • Protect the personal safety of users of the Service or the public

• • Protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use Global best practice commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

However, it is important to note that your password is the key to your account. Please use unique numbers, letters and special characters, and do not share your password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password. You are reminded to log off from your account and close the browser when finished while using a shared computer.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Links to Other Sites

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child or children have provided us with personal data, please contact us at support@mtncoop.com . If we become aware that we have collected personal data from children without verification of parental consent, we shall take steps to remove that information from our servers.

Your Data Privacy Rights

• • Right to Rectification: Users can modify or change their name, email, password, and mobile login PIN via their profile.

• • Right of Access and Erasure: Users can request access or erasure of their personal information, as well as request restriction on further processing of their personal information by contacting us at support@mtncoop.com. Please allow up to 30 days for requests to be processed. We reserve the right to charge a reasonable fee to process excessive or repeated requests.

• • Right to Withdraw Consent: Users can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send, or by adjusting your Marketing Preferences in your profile. Users also have choices with respect to cookies, as described above. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Service may not work properly in your case.

• • Right to lodge a complaint with a supervisory authority: Should you feel your data privacy rights are not being adequately protected by us, you have the right to lodge a formal complaint with the appropriate supervisory authority.

Changes to this Privacy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact us if you have questions regarding your data privacy rights or would like to submit a related data privacy right request, please email us at support@mtncoop.com and allow up to 30 days for requests to be processed.